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PAS 79-2:2020

Fire risk assessment –


Part 2: Housing – Code of practice
Publishing and copyright information
The BSI copyright notice displayed in this document indicates when the document
was last issued.
© The British Standards Institution 2020. Published by BSI Standards Limited 2020.
ISBN 978 0 539 06260 1
ICS 13.220.20
No copying without BSI permission except as permitted by copyright law

Publication history
First published December 2020
PAS 79-2:2020

Contents
Foreword ..................................................................................................... iii
Introduction ................................................................................................. vi
1 Scope ......................................................................................................... 1
2 Normative references .............................................................................. 2
3 Terms and definitions .............................................................................. 2
4 The concepts of fire risk and fire hazard ................................................ 11
5 Principles and scope of fire risk assessments ........................................ 12
6 Responsibility for adequacy of the fire risk assessment ....................... 16
7 Competence of fire risk assessors ........................................................... 19
8 Benchmark standards for assessment of fire precautions .................... 21
9 Assessment of premises design and fire precautions
that do not conform to current standards ................................................ 24
10 Documentation of fire risk assessments .............................................. 27
11 Nine steps to fire risk assessment ........................................................ 29
12 Information about the premises and their occupants ........................ 31
13 Identification of fire hazards and means for their elimination
or control ..................................................................................................... 34
14 Assessment of the likelihood of fire .................................................... 36
15 Assessment of fire protection measures .............................................. 37
16 Assessment of fire safety management ............................................... 52
17 Assessment of likely consequences of fire .......................................... 57
18 Assessment of fire risk .......................................................................... 59
19 Formulation of an action plan .............................................................. 60
20 Periodic review of fire risk assessments .............................................. 63
21 Type 2, Type 3 and Type 4 fire risk assessments .................................. 65
22 Person-centred fire risk assessments .................................................... 68
Annexes
Annex A (informative)
Model pro forma for documentation of a fire risk assessment ............... 69
Annex B (informative)
Fire hazard prompt-list ............................................................................... 91
Annex C (normative)
Key factors to consider in assessment of means of escape ....................... 92
Annex D (informative)
Model pro forma for documentation of a review of an existing fire
risk assessment ............................................................................................ 95
Annex E (informative)
Model pro forma for a person-centred fire risk assessment .................... 106
Annex F (informative)
Model matrix of responsibilities for fire safety measures in
specialized housing ..................................................................................... 110
Annex G (informative)
Exemplar of a completed fire risk assessment ........................................... 112
Bibliography ................................................................................................ 134

© The British Standards Institution 2020 i


PAS 79-2:2020

List of figures
Figure 1 – Schematic of fire risk assessment process ................................. 14
Figure 2 – Decision tree for action plan when existing premises do
not conform to current standards .............................................................. 26
Figure 3 – Example of timeline comparison between ASET and RSET .... 58
List of tables
Table 1 – An example of a simple risk level estimator .............................. 59
Table C.1 – Key factors and specific issues to consider in
means of escape .......................................................................................... 93

ii © The British Standards Institution 2020


PAS 79-2:2020

Foreword
Publishing information The PAS process enables a code of practice to be
rapidly developed in order to fulfil an immediate
The development of this PAS was facilitated by BSI need in industry. A PAS can be considered for further
Standards Limited and published under licence from development as a British Standard, or constitute part
The British Standards Institution. It came into effect on of the UK input into the development of a European or
31 December 2020. International Standard.

Acknowledgement is given to Colin Todd, as the


technical author, and the following organizations
Supersession
that were involved in the development of this PAS as
members of the steering group: Together with PAS 79-1, this part of PAS 79 supersedes
• CBRE PMFM UK PAS 79:2012, which is withdrawn.

• Consumer and Public Interest Network


• Fire Industry Association Relationship with other publications
• Institution of Fire Engineers
PAS 79 is published in two parts:
• Lendlease
• Part 1: Premises other than housing – Code of
• Metro Safety Ltd practice;
• National Fire Chiefs Council • Part 2: Housing – Code of practice.
• National Residential Landlords Association
• National Security Inspectorate PAS 9980, which is in the course of preparation at
the time of publication of this current PAS, will give
• National Social Housing Fire Strategy Group
recommendations for fire risk appraisal and assessment
• NHS England/NHS Improvements of external wall construction and cladding of blocks
• Savills (UK) Limited of flats.
• Scottish Fire and Rescue Service
• University College London
Information about this document
Acknowledgement is also given to the members of This PAS is a new, second part of the original PAS 79.
a wider review panel who were consulted in the That PAS was first prepared in 2005 by BSI in association
development of this PAS. with C.S. Todd & Associates Ltd, with the support and
encouragement of the Institution of Fire Engineers
This PAS has been developed and published by BSI, and the Northern Ireland Fire Safety Panel, the latter
which retains its ownership and copyright, except of which represents building control and licensing
for Annex A, Annex D and Annex G, for which the authorities in Northern Ireland and the Northern
copyright is owned by C.S. Todd & Associates Ltd Ireland Fire & Rescue Service. It was subsequently
(see Use of this document), and Annex E and Annex F, revised in 2007 and 2012. Those revisions, a new
which are reproduced from Fire safety in specialised PAS 79-1, which excludes housing from its scope, and
housing with the permission of the National Fire Chiefs this new Part 2 of PAS 79, which relates specifically to
Council. BSI Standards Limited as the publisher of the housing, were again, drafted by C.S. Todd & Associates
PAS reserves the right to withdraw or amend this PAS Ltd. This new Part 2 was developed by C.S. Todd &
on receipt of authoritative advice that it is appropriate Associates Ltd at the request of the housing sector.
to do so. This PAS will be reviewed at intervals not
exceeding two years. This new Part 2 of PAS 79 is based on PAS 79:2012, but
introduces the following principal changes.
This PAS is not to be regarded as a British Standard.
• PAS 79 has been split into two parts, with PAS 79-1
It will be withdrawn upon publication of its content
dealing with non-housing premises and PAS 79-2
in, or as, a British Standard.
dealing with housing premises.

© The British Standards Institution 2020 iii


PAS 79-2:2020

• The scope of this new Part 2 of PAS 79 comprises required in the case of fire risk assessors who carry
blocks of flats, sheltered housing, extra care housing, out fire risk assessments of high-risk residential
supported housing and certain houses in multiple buildings. It is also noted in this PAS that fire safety
occupation (i.e. those falling within the scope of the specialists with experience only in the design of
relevant fire safety legislation). Fire risk assessment new buildings might not possess an appreciation
for other, non-housing premises is addressed in a new of standards against which older buildings were
Part 1 of PAS 79. designed and the possible continued acceptability of
• PAS 79-2 is a code of practice, whereas PAS 79:2012 such standards.
was a guide. PAS 79:2012 was already written in the • There is new, more detailed discussion of the stay
form of a code of practice, and the change in status put strategy normally adopted in blocks of flats and
is simply to recognize this, noting that guides are not maisonettes, and this term, as well as the converse
usually of such a nature as to sustain a reliable claim strategy of simultaneous evacuation, is now defined
of compliance. in this PAS.
• Guidance, published in England by the Local • A warning is included in respect of the potential risk
Government Association, on fire safety in to residents if a stay put strategy is inappropriately
purpose‑built blocks of flats [1] has been taken into abandoned.
account, along with equivalent guidance for high- • Reference is made to evacuation alert systems for use
rise blocks of flats published in Scotland by Scottish by the fire and rescue service in blocks of flats and
Government1) [2]. maisonettes, which are the subject of BS 8629.
• Guidance produced by the National Fire Chiefs • Reference is made to person-centred fire risk
Council on fire safety in specialized housing [3] has assessments in specialized housing, though specific
been taken into account, along with equivalent recommendations for these fire risk assessments are
guidance published in Scotland by Scottish outside the scope of this PAS.
Government [4].
• Changes to, and publication of relevant new, British
• For blocks of flats, sheltered housing and extra care Standards have been taken into account.
housing, recommendations are provided for Type 2,
Type 3 and Type 4 fire risk assessments, as defined This publication can be withdrawn, revised, partially
in the Local Government Association guidance [1] superseded or superseded. Information regarding the
and the National Fire Chiefs Council guidance [3]. status of this publication can be found in the Standards
However, for these housing premises, this PAS Catalogue on the BSI website at bsigroup.com/
is primarily concerned with the Type 1 fire risk standards, or by contacting the Customer Services team.
assessment required for compliance with the relevant
fire safety legislation in England and Wales. Where websites and webpages have been cited, they
• The technical content has been subject to amendment are provided for ease of reference and are correct at
in the light of experience in the use of PAS 79:2012. the time of publication. The location of a webpage or
• There is new guidance on the consideration to be website, or its contents, cannot be guaranteed.
given to external wall construction and cladding,
which takes into account knowledge, current at the
time of publication, arising from the fire disaster at Use of this document
Grenfell Tower, a high-rise block of flats in London, As a code of practice, this PAS takes the form of
in 2017. guidance and recommendations. It should not be
• There is recognition of pre-occupation fire safety quoted as if it were a specification, and particular care
assessments, a term now defined in this PAS, and should be taken to ensure that claims of compliance are
a clarification to avoid confusion between these not misleading.
assessments and the fire risk assessment to which this
PAS refers. Any user claiming compliance with this PAS is expected
• There is even greater emphasis on competence of fire to be able to justify any course of action that deviates
risk assessors and reference to future competence from its recommendations.
standards in consequence of the Hackitt Review
It has been assumed in the drafting of this PAS that
of building regulations and fire safety, which was
the execution of its provisions will be entrusted to
ordered by the Government following the fire at
appropriately qualified and competent people, for
Grenfell Tower, and the recommendation of that
whose use it has been produced.
Review that an enhanced level of competence is

1)
The equivalent guidance in Scotland relates only to high-rise, purpose-built blocks of flats.

iv © The British Standards Institution 2020


PAS 79-2:2020

The copyright for Annex A, Annex D and Annex G of the recommendations. Commentaries give background
this PAS, and for the electronic copies of the separately information.
available pro formas (including the modified versions
for use in Scotland and Northern Ireland), is owned by It is envisaged that, when a fire risk assessment is
C.S. Todd & Associates Ltd. Purchasers of this PAS are audited for compliance with this PAS, the audit will be
authorized to use the pro formas contained within based on the recommendations only.
Annex A and Annex D, and the separately available
electronic copies, and to make an unlimited number
of copies for their own use, without infringement of Contractual and legal considerations
copyright. However, following the recommendations
This PAS does not purport to include all the necessary
given in this PAS does not necessitate use of these
provisions of a contract. Users are responsible for its
pro formas.
correct application.
This PAS is not intended to constitute a textbook on
Compliance with a PAS cannot confer immunity from
fire safety, and it is not to be regarded as a substitute
legal obligations.
for knowledge of fire safety principles and the practical
use and application of fire protection measures or an
Attention is drawn to the legislation described in the
understanding of the premises, their features, usage
Introduction to this PAS and to guidance available
and occupancy. In carrying out the fire risk assessment,
from the Ministry of Housing, Communities and Local
there is likely to be a need for reference to other codes
Government, Scottish Government and the Northern
of practice and guidance documents on specific aspects
Ireland Fire & Rescue Service.
of fire prevention, fire protection and management
of fire safety, a number of which are listed in the At the time of publication of this PAS, a Public Inquiry,
Bibliography. Moreover, this PAS is not intended to ordered by the Government, into the 72 deaths that
provide guidance on the detailed requirements of the occurred in the Grenfell Tower fire is in progress.
relevant fire safety legislation. Such guidance can be Nothing in this PAS pre-empts, or is intended to conflict
found in the relevant government guidance documents with, any future findings of that Public Inquiry.
listed in the Bibliography.

Presentational conventions
The provisions of this PAS are presented in roman
(i.e. upright) type. Its recommendations are expressed
in sentences in which the principal auxiliary verb is
“should”.

Commentary, explanation and general informative


material is presented in smaller italic type, and does
not constitute a normative element.

Where words have alternative spellings, the preferred


spelling of the Shorter Oxford English Dictionary is used
(e.g. “organization” rather than “organisation”).

The word “should” is used to express recommendations


of this PAS. The word “may” is used in the text to
express permissibility, e.g. as an alternative to the
primary recommendation of the clause. The word “can”
is used to express possibility, e.g. a consequence of an
action or an event.

Notes and commentaries are provided throughout the


text of this PAS. Notes give references and additional
information that are important but do not form part of

© The British Standards Institution 2020 v


PAS 79-2:2020

Introduction
Persons who have control of the housing premises to immediate vicinity of the premises who is at risk from a
which this PAS applies are required by legislation to fire on the premises, but not firefighters at the time of
carry out an assessment of the fire risks (other than fire a fire.)
risks within private dwellings). This is to ensure that
relevant persons (as defined within the legislation) are The same duty is imposed on every person, other
safe from fire and its effects (other than in the case than the responsible person, who has, to any extent,
of blocks of flats, sheltered housing and extra care control of the premises so far as the duty relates to
housing in Scotland and Northern Ireland). For the matters within their control. (This normally includes, for
purposes of this PAS, a fire risk assessment carried out example, the managing agents of a block of flats.)
in the structured manner described herein is referred
to as “the fire risk assessment” or “the FRA”. Guidance on the requirements of the Fire Safety
Order in all premises in which people sleep, and on
In England and Wales, the single, unified fire safety the FRA required by it, was produced by the then
legislation, under which fire safety is controlled in Department for Communities and Local Government
the vast majority of existing buildings, namely the (DCLG) (now the Ministry of Housing, Communities
Regulatory Reform (Fire Safety) Order 2005 (the and Local Government) in 2006 [6]. For purpose-built
“Fire Safety Order”) [5], excludes domestic premises blocks of flats and specialized housing, that guidance
from its scope. However, for the purposes of the Fire is largely superseded by guidance produced by the
Safety Order, “domestic premises” do not include Local Government Association [1] and the National Fire
premises used in common by the occupants of more Chiefs Council [3] respectively. In the case of HMOs,
than one private dwelling. the original DCLG guidance is of some relevance,
but guidance originally produced by the then Local
Accordingly, the Fire Safety Order applies to the Authority Coordinators of Regulatory Services
common parts and non-domestic areas (e.g. plant (LACoRS) [7] is more relevant.
rooms) within general needs blocks of flats, sheltered
housing and extra care housing. The Fire Safety The guidance in this PAS is more detailed in respect of
Order also normally applies to, at least, the common the FRA process than that contained in the guidance
parts of supported housing designed for vulnerable documents to which the previous paragraph refers, but
people with common characteristics, living as part of does not conflict with them. However, these guidance
a community with support. In the case of a house in documents provide more detailed technical information
multiple occupation (HMO), in which occupants live on the fire safety measures that are needed to meet
independently within their own accommodation (as legislation.
opposed to simply sharing the entire house), the Fire
Safety Order applies only to the common circulation While, in England and Wales, the Fire Safety Order
areas of the property. Where no common circulation requires that the FRA is “suitable and sufficient”, this
areas exist in an HMO in England or Wales, the Fire requirement is not explicitly stated in the equivalent
Safety Order and accordingly PAS 79-2 do not apply, legislation in Scotland or Northern Ireland, though,
regardless of any requirement for a licence. clearly, all assessments need to be fit for purpose.

Article 9 of the Fire Safety Order requires that the In Scotland, the equivalent legislation to the Fire Safety
responsible person, on whom the Fire Safety Order Order comprises the Fire (Scotland) Act 2005 [8] in
imposes requirements (such as the freeholder of a block conjunction with the Fire Safety (Scotland)
of flats), make a suitable and sufficient assessment of Regulations 2006 [9]. The scope of this legislation
the risks to which relevant persons are exposed for the comprises “relevant premises”, which, as in England
purpose of identifying the general fire precautions and Wales, exclude domestic premises. However, in
they need to take to comply with the requirements contrast with the Fire Safety Order in England and
and prohibitions imposed on them by or under the Fire Wales, for the purpose of the Scottish fire safety
Safety Order. (For the purpose of the Fire Safety Order, legislation, the term “domestic premises” includes
“a relevant person” is any person who is, or might be, within its meaning parts of premises used in common
lawfully on the premises, and also any person in the by the occupants of more than one private dwelling.

vi © The British Standards Institution 2020


PAS 79-2:2020

Accordingly, the Scottish fire safety legislation does In Northern Ireland, the requirements for FRAs are
not apply to any parts of general needs blocks of flats, identical to those in Scotland, but are imposed by
sheltered housing and extra care housing (other than Articles 25(2)(a) and 26(2)(a) of the Fire and Rescue
in relation to maintenance and repair of facilities, Services (Northern Ireland) Order 2006 [13]. As in
equipment and devices required under legislation for Scotland, further requirements in respect of the FRAs are
use by, or protection of, firefighters and in relation to imposed by secondary legislation, namely the Fire Safety
places of work within these premises). Therefore, the Regulations (Northern Ireland) 2010 [14]. As in Scotland,
FRAs for these premises, to which this PAS refers, are the FRAs to which his PAS applies are not required for
not required under legislation in Scotland, although blocks of flats, sheltered housing and extra care housing,
the Civic Government (Scotland) Act 1982 [10] but they are required for HMOs as defined in
places responsibilities upon occupiers to maintain Section 1 of the Houses in Multiple Occupation
common areas free of combustible materials and to (Northern Ireland) Act 2016 [15]. Guidance on the
maintain access and egress from the property free requirements of Northern Ireland fire safety legislation,
of obstructions. However, in Scotland, the fire safety and the FRA required by it, has been published by the
legislation does apply to HMOs that, under the Housing Department of Health, Social Services and Public Safety [16].
(Scotland) Act 2006 [11], require a licence; these Again, PAS 79 does not conflict with this guidance,
premises do require an FRA of the type described in which gives greater technical information on fire safety
this PAS. measures required by legislation.

In Scotland, the duty to carry out an FRA is imposed on Fire and rescue authorities can advise on the fire
every employer by section 53(2)(a) of the Fire (Scotland) safety legislation that applies to any premises, and
Act 2005 [8]. The Act requires that the risk assessment on means for compliance. If in doubt regarding the
identifies any risks to the safety of the employer’s requirements of legislation, consultation with the fire
employees in respect of harm caused by fire in the and rescue authority is strongly recommended. Advice
workplace. Section 54(2)(a) of the Act also imposes a can also be obtained from a suitably qualified and
duty, on any person who has control to any extent of experienced fire risk assessor or fire safety practitioner.
relevant premises, to carry out an FRA, and this risk A number of bodies maintain a register of persons
assessment is required to identify any risks to the safety who they consider competent to carry out FRAs. These
of relevant persons in respect of harm caused by fire include relevant professional bodies, and certification
in the relevant premises; the term “relevant persons” bodies accredited by UKAS2) to provide assessment and
is defined in much the same manner as it is defined in certification services. Registration of a fire risk assessor
the Fire Safety Order in England and Wales. Fire safety on such a register can give the dutyholder confidence
duties are also imposed, under Section 54(4) of the Fire in the education, training and experience of the fire
(Scotland) Act 2005 [8], on persons who have, under risk assessor if the dutyholder wishes to use the fire risk
a contract or tenancy, an obligation of any extent in assessor’s services.
relation to maintenance or repair of relevant premises,
or anything in relevant premises, or safety in respect of Legislation requires “suitable and sufficient”
harm caused by fire in relevant premises. assessments to ensure that organizations comply
with health and safety legislation. Accordingly,
In Scotland, further requirements in respect of the an organization could choose to carry out, and
FRAs required by the Fire (Scotland) Act 2005 [8] document, a single combined health, safety and fire
are imposed by the Fire Safety (Scotland) risk assessment. In practice, this approach is normally
Regulations 2006 [9]. Guidance on the requirements of only adopted in the case of very small premises, and
this legislation, and the FRA required by it, is published most organizations choose to carry out a separate FRA,
by Scottish Government [12]. As in England and Wales, independent of their health and safety risk assessment.
the guidance in this PAS is more detailed in respect The reason for this is that, for most premises, different
of the FRA process than the guidance in the Scottish skills, experience and expertise are required for each of
Government guidance documents, but does not conflict the two forms of risk assessment.
with them. However, the Scottish Government guidance
provides more technical information on the fire safety
measures required under the Scottish fire safety
legislation.

UKAS is the sole national accreditation body recognized by government to assess, against internationally agreed standards,
2)

organizations that provide certification, testing, inspection and calibration services.

© The British Standards Institution 2020 vii


PAS 79-2:2020

The term “suitable and sufficient” (as used in the Fire This PAS does not purport to contain a methodology
Safety Order) is not defined in legislation. Moreover, or documentation that is necessarily superior to all
throughout the UK, the relevant fire safety legislation others. It takes into account the fire safety legislation
(see 3.79) requires that the “significant findings” of the that is current at the time of publication. The fire
risk assessment, and any group of persons “especially at risk assessment methodology is intended to facilitate
risk”, be recorded if the organization employs five or protection of occupants of housing premises,
more people (in the entire organization, and not just particularly residents, from fire (but not necessarily a
in the premises in question), or if legislation requires fire within their own private dwelling). Guidance on
licensing, registration or certification of the premises, fire precautions to protect property, and to protect
or if an alterations notice (requiring that the relevant against interruption to business, from fire can be
enforcing authority is notified of proposals to carry out obtained from property insurers, and many suitably
certain alterations to the premises) is in force. Again, qualified and experienced fire safety consultants can
the terms “significant findings” and “especially at risk” advise on these issues as well as on life safety.
are not defined in the relevant legislation. However,
the “significant findings” ought to indicate measures The objectives of this PAS are:
taken and measures that will be taken for compliance • to present to housing providers and their advisers a
with the legislation. methodology that can assist them in meeting their
legislative responsibilities to undertake FRAs;
Nevertheless, it follows that the adequacy of any FRA
• to provide a framework for the assessment of fire risk;
is a matter for subjective judgement. This can lead,
and has led, to inconsistency in interpretation, creating • to promote better understanding of fire risks and fire
some difficulties for housing providers, their advisers safety in housing by housing providers and non-fire
and enforcing authorities. These difficulties have been specialists;
exacerbated, even for fire safety specialists, by a distinct • to enable common relevant terminology to be
move, in recent years, towards “risk-proportionate” adopted by those who carry out FRAs;
fire precautions, and away from the more traditional • to provide an understanding of the principles and
“prescriptive” approach in which there was often a scope of FRAs;
more rigid application of codes of practice without full
• to establish a pragmatic, holistic and risk-
consideration of fire risk.
proportionate approach towards assessment of
fire prevention measures, fire protection measures
This shift was designed to benefit those who own and
and management of fire safety, for the purpose
manage premises, since it provides a better match
of conducting FRAs in housing, based upon a
between risk and precautions, more akin to that found
fundamental understanding of fire safety principles;
in the field of general health and safety. It therefore
precludes unnecessary expenditure in circumstances • to establish a satisfactory basis for documentation of
in which the risk does not justify it. Equally, it ensures housing FRAs;
adequate protection (possibly to an even higher • to provide a benchmark for a suitable and
standard than applied under prescriptive codes) when sufficient FRA;
warranted by the fire risk. Ultimately, the final arbiter • to promote a consistent approach to carrying out and
as to whether fire precautions satisfy legislation can, documenting an FRA that is likely to be satisfactory to
however, only be the Courts. enforcing authorities; and
• to dispel misconceptions as to the nature and scope
There is, therefore, no single correct or incorrect
of an FRA (see Clause 5).
method of carrying out and recording the significant
findings of an FRA. Rather, there are many approaches
This PAS also provides recommendations for
that can lead to a suitable, and satisfactorily
Type 2, Type 3 and Type 4 FRAs, as defined in the Local
documented, FRA, which, at first sight at least, bear
Government Association guidance on fire safety in
little similarity. Nevertheless, the prerequisites for a
purpose-built blocks of flats [1], and the National Fire
suitable and sufficient FRA are implicit in legislation
Chiefs Council guidance on fire safety in specialized
and, accordingly, close scrutiny of most adequate FRAs
housing [3], the scope of which either exceeds the
will reveal consideration of many common factors.
minimum requirements of fire safety legislation or is
completely outside the scope of the legislation.

viii © The British Standards Institution 2020


PAS 79-2:2020

The person on whom a duty is imposed to carry out


the FRA is described in different ways in different
legislation across the UK. For example, as noted above,
in England and Wales, the Fire Safety Order describes
the person as the “responsible person”, whereas this
term is not used elsewhere in the UK. Moreover, this
duty can be imposed on more than one person within
the same premises (e.g. freeholders and managing
agents). In this PAS, the term “dutyholder” is used to
describe any person on whom the relevant fire safety
legislation imposes a requirement to carry out an FRA
in housing premises.

This part of PAS 79 is only concerned with housing


premises. PAS 79-1 provides recommendations for FRAs
in non-domestic premises. Therefore, in the case of
mixed use premises (e.g. commercial and residential),
it is necessary to refer to the recommendations of both
PAS 79-1 and PAS 79-2.

At the time of publication of this PAS, there are,


potentially, certain restrictions in the measures that
can be taken by a fire risk assessor to comply with
the recommendations of this PAS, arising from the
COVID-19 pandemic. For example, in a block of flats,
health and safety considerations might take precedence
over fire risk assessment, such as to preclude the level
of inspection of flat entrance doors recommended in
this PAS.

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PAS 79-2:2020

This page is deliberately left blank.

x © The British Standards Institution 2020


PAS 79-2:2020

1 Scope

This part of PAS 79 gives recommendations and The recommended approach to carrying out fire
corresponding examples of documentation for risk assessments is intended to determine the
undertaking, and recording the significant findings of, risk-proportionate fire precautions required to protect
fire risk assessments in housing premises and parts of occupants of housing premises, particularly residents,
housing premises for which fire risk assessments are but also employees, contractors and visitors to the
required by legislation. Recommendations are also premises, and to protect people in the immediate
provided for fire risk assessments that are outside the vicinity of the premises. The fire risk assessment is
scope of fire safety legislation, but are designed to not necessarily sufficient to address the safety of
protect residents of blocks of flats, sheltered housing firefighters in the event of a fire on the premises,
and extra care housing in the event of a fire in their as firefighters are not “relevant persons” within the
own flat. meaning of the relevant fire safety legislation.

This part of PAS 79 is applicable to: The recommended methodology is not intended to
a) certain houses in multiple occupation [i.e. those address protection of property (the premises and their
falling within the scope of the relevant fire safety contents) or the environment, or to address protection
legislation (see 3.79)]; of a business against interruption.
b) the common parts of blocks of flats or maisonettes,
sheltered housing and extra care housing; and
c) supported housing.

This part of PAS 79 is not applicable to a single-family


private dwelling, or a shared house in England or
Wales. Neither is it applicable to premises during the
construction phase3), before the building is used as
housing, but it is applicable to vacant premises, for
which a fire risk assessment is required.

This part of PAS 79 is not applicable to premises used


solely for short-term letting (e.g. of flats) (see 3.84) or
peer-to-peer rented accommodation (see 3.70), nor to
non-domestic premises or residential care homes.
NOTE These types of premises are covered in PAS 79‑1.

The methodology in this PAS provides a structured


approach to fire risk assessment for people with
knowledge of the principles of fire safety; it is not a
guide to fire safety.

3)
Fire risk assessments are required for construction sites. Nevertheless, fire risk assessments for housing premises, during the
construction phase, are outside the scope of this PAS.

© The British Standards Institution 2020 1


PAS 79-2:2020

2 Normative references 3 Terms and definitions

The following documents are referred to in the text in For the purposes of this PAS, the terms and definitions
such a way that some or all of their content constitutes given in BS 4422, BS EN ISO 13943 and the following
provisions of this document4). For dated references, only apply.
the edition cited applies. For undated references, the
latest edition of the referenced document (including 3.1 access room
any amendments) applies.
room that forms the only escape route from an inner
BS 4422, Fire – Vocabulary 5) room (see 3.57)

BS 5839-6:2019, Fire detection and fire alarm systems 3.2 action plan
for buildings – Part 6: Code of practice for the design,
installation, commissioning and maintenance of fire measures, including management procedures,
detection and fire alarm systems in domestic premises identified in the course of a fire risk assessment that
need to be implemented to ensure that the required
BS EN ISO 13943, Fire safety – Vocabulary level of fire safety is achieved or maintained
NOTE The required level of fire safety is normally
defined within the organization’s fire safety policy,
but is never of a lower standard than that required by
legislation.

3.3 alarm receiving centre


continuously manned premises, remote from those
in which a fire alarm system is fitted, where the
information concerning the state of the fire alarm
system is displayed and/or recorded, so that the fire and
rescue service can be summoned

3.4 alternative escape routes


escape routes sufficiently separated either by direction
and space, or by fire-resisting construction, intended to
ensure that if one is affected by fire the other will still
be available

3.5 automatic door release mechanism


device that can be used for holding a door in the
open position, against the action of a door closer, and
automatically releasing under specified conditions

4)
Documents that are referred to solely in an informative manner are listed in the Bibliography.
5)
This PAS also gives informative references to BS 4422:2005.

2 © The British Standards Institution 2020


PAS 79-2:2020

3.6 available safe escape time (ASET) 3.15 dampers


time available between ignition of a fire and the 3.15.1 fire damper
time at which tenability criteria (for safety of life) are
mobile closure or intumescent device within a duct,
exceeded in a specific space in a building
which is operated automatically and is designed to
NOTE To ensure the safety of occupants, the required prevent the passage of fire and which, together with
safe escape time (RSET) (see 3.80) needs to be shorter its frame, is capable of satisfying for a stated period
than the ASET. of time the same fire resistance criterion for integrity
as the element of the building construction through
3.7 class A fire which the duct passes

fire involving solid materials, usually of an organic 3.15.2 fire/smoke damper


nature, in which combustion normally takes place with combined fire and smoke damper
the formation of glowing embers NOTE See fire damper (3.15.1) and smoke
NOTE These are normally carbonaceous fires. damper (3.15.3).

3.8 class B fire 3.15.3 smoke damper

fire involving liquids or liquefiable solids mechanical device which, when closed, prevents smoke
passing through an aperture within a duct or structure
NOTE In any particular premises, smoke dampers might
3.9 class C fire
be automatically operated, or manually operated, or
fire involving gases a combination of the two, and their normal position
might be either open or closed.
3.10 class D fire
fire involving metals 3.16 dead end
area from which escape from fire is possible in one
3.11 class F fire direction only, or in directions less than 45° apart that
are not separated by fire-resisting construction
fire involving fats and cooking oils
NOTE A dead end is not created solely by structural
enclosure. It can, for example, be created by barriers
3.12 combustible such as steps, narrow escape routes, convoluted escape
capable of burning in the presence of oxygen in a routes or heavy doors.
standard test condition
3.17 dry fire main
3.13 compartmentation water supply pipe installed in a building for firefighting
subdivision of a building by fire-resisting walls and/or purposes, fitted with inlet connections at the fire and
floors for the purpose of limiting fire spread within the rescue service access level, and with landing valves at
building specified points, which is normally dry but is capable of
being charged with water, usually by pumping from fire
and rescue service appliances
3.14 competent person
person, suitably trained and qualified by knowledge
and practical experience, and provided with the
necessary instructions, to enable the required task(s) to
be carried out correctly
NOTE The relevant fire safety legislation requires
nomination of various competent persons to carry out a
number of different defined tasks.

© The British Standards Institution 2020 3


PAS 79-2:2020

3.18 dutyholder 3.23 extra care housing


person on whom legislation imposes a requirement to housing of a similar nature to sheltered housing
carry out a fire risk assessment (though sometimes including residents with disabilities
NOTE 1 The term “dutyholder” only has meaning that are not age-related), but with managed on-site
within this PAS, and is used for convenience. It is not a care and support service, commonly on a 24 h basis
term used in this context within fire safety legislation, NOTE This includes premises sometimes described as
in which the dutyholder could be a number of different very sheltered housing, “housing with care”, “assisted
parties according to circumstances, e.g. in England and living” and “integrated care and housing (ICH)” or,
Wales, the responsible person, to which the Fire Safety where support is linked to a care home, “close care
Order [5] makes reference, is one such dutyholder. housing”.
NOTE 2 The dutyholder can be determined from the
relevant fire safety legislation. 3.24 false alarm
NOTE 3 The dutyholder is normally an organization, fire signal resulting from a cause(s) other than fire
such as an employer, rather than a specific named
person.
3.25 final exit
NOTE 4 There might be more than one dutyholder
within any premises. For example, in supported termination of an escape route from a building, giving
housing, dutyholders might comprise the service direct access to a street, passageway, walkway or open
provider (as an employer), the landlord (as the person space, and sited to enable the rapid dispersal of persons
having control of the premises) and possibly even from the vicinity of a building so that they are no
the local authority commissioners (as a result of their longer in danger from fire and/or smoke
contract with the service provider). In the case of a
purpose-built block of flats in England and Wales, 3.26 fire audit
dutyholders might comprise the freeholder and
managing agents (as persons having control of the systematic examination to determine whether
premises) and, possibly, even leaseholders (e.g. if, under standards of fire safety conform to those required in
their lease, they are responsible for maintenance and order to achieve the organization’s fire safety policy
repair of their flat entrance doors). and objectives

3.19 emergency escape lighting 3.27 fire door


part of the emergency lighting that provides door or shutter provided for the passage of people, air
illumination for the safety of people leaving a location or objects which, together with its frame and furniture
or attempting to terminate a potentially dangerous as installed in a building, is intended (when closed)
process before doing so to resist the passage of fire and/or gaseous products
of combustion, and is capable of meeting specified
performance criteria to those ends
3.20 emergency lighting
lighting provided for use when the supply to the 3.28 fire drill
normal lighting fails
periodic test of the evacuation procedure involving
participation of the occupants of a building and, where
3.21 escape route relevant and practicable, any other actions required as
route forming part of the means of escape from any part of the fire procedure
point in a building to a final exit NOTE This is sometimes known as an evacuation drill,
e.g. in BS 4422:2005.
3.22 evacuation alert system for use by
the fire and rescue service 3.29 fire equipment sign
system intended for installation in a building safety sign that indicates the location or identification
containing flats or maisonettes to enable the fire and of fire equipment or how it is to be used
rescue service to initiate an evacuation alert signal
by means of evacuation devices within the flats or
maisonettes, using manual controls incorporated within
control equipment

4 © The British Standards Institution 2020


PAS 79-2:2020

3.30 fire exposure 3.39 fire risk


extent to which people, animals or items are subjected combination of the likelihood of the occurrence of fire
to the conditions created by fire and consequence(s) likely to be caused by a fire
NOTE In the context of this PAS, the relevant
3.31 fire hazard consequences of a fire are those involving injury to
people (number and severity of injuries), as opposed to
source, situation or act with potential to result in a fire
damage to property.
NOTE Examples of fire hazards include ignition sources,
accumulation of waste that could be subject to ignition,
and disposal of a lit cigarette close to combustible
3.40 fire risk assessment (FRA)
materials. process of identifying fire hazards and evaluating the
risks to people arising from them, taking into account
3.32 fire hazard identification the adequacy of existing fire precautions, and deciding
whether or not the fire risk is acceptable without
process of recognizing that a fire hazard exists and further fire precautions
defining its characteristics
NOTE 1 A fire risk assessment is a legal requirement for
certain multiple-occupancy dwellings and parts of such
3.33 fire load dwellings.
quantity of heat that could be released by the complete NOTE 2 Where the fire risk is not acceptable without
combustion of all the combustible materials in a further fire precautions, a fire risk assessment includes
volume, including the facings of all bounding surfaces an action plan that sets out reasonably practicable
measures to reduce the risk.

3.34 fire precautions


3.41 fire risk assessor
physical, procedural and managerial measures taken
to reduce the likelihood of ignition occurring and/or to person who carries out, and documents the significant
mitigate the consequences if ignition does occur findings of, a fire risk assessment
NOTE The fire risk assessor is expected to be a
3.35 fire prevention measures competent person (see 3.14), and the fire risk assessor
has a duty of care to the dutyholder on which
measures to prevent the outbreak of fire legislation imposes a requirement for the fire risk
assessment. However, the ultimate responsibility for
3.36 fire procedure the adequacy of the fire risk assessment rests with the
dutyholder (which could be an organization – see 3.18
predetermined actions to be taken in the event of fire
and related notes) rather than with the fire risk assessor
(see Clause 6).
3.37 fire protection measures
design features, systems, equipment or structural 3.42 fire safety engineer
measures to reduce danger to people and property if
person suitably qualified and experienced in fire safety
fire occurs
engineering
NOTE Examples of such measures include means of
detecting, extinguishing or containing fires.
3.43 fire safety engineering
3.38 fire resistance application of scientific and engineering principles
to the protection of people, property and the
ability of an item to fulfil for a stated period of time environment from fire
the required load-bearing capacity and/or integrity
and/or thermal insulation, and/or other expected duty
specified in a standard fire resistance test
NOTE This is not the time that the item can withstand
exposure to any specific real fire without loss of its
required performance.

© The British Standards Institution 2020 5


PAS 79-2:2020

3.44 fire safety induction training 3.52 fire stopping


formal training, normally given verbally to new sealing or closing an imperfection of fit between
employees as soon as practicable after their elements, components or constructions of a building,
employment, with the objective of imparting sufficient or any joint, so as to restrict penetration of smoke and
information on the relevant fire risks, fire prevention flame through the imperfection or joint
measures, fire protection measures and fire procedures
in the building to ensure the safety of employees 3.53 fire strategy
from fire
set of fire safety objectives and the measures to be
NOTE Fire safety induction training also assists in
taken to meet those objectives
preventing employees from inadvertently putting other
occupants of the premises at risk from fire.
3.54 house in multiple occupation (HMO)
3.45 fire safety management house that is occupied by persons who do not form a
single household
task(s) carried out by a defined individual or individuals
with appropriate powers and resources to ensure that NOTE For the purposes of housing legislation, and
the fire safety systems, passive, active and procedural, requirements made thereunder, the term “HMO” is
within the building are working properly at all times subject to specific definitions in England and Wales and
the devolved regions.

3.46 fire safety manager


3.55 ignition
person nominated to monitor and control the
management of fire safety initiation of combustion

3.47 fire safety manual 3.56 ignition source


record of all design, procedural and management issues source of energy that initiates combustion
and events that relate to the fire safety of a building
3.57 inner room
3.48 fire safety objective room from which the only escape route is through
specified (or specifiable) goal intended to be achieved another room
by a fire protection measure(s) NOTE The room that provides the escape route from an
inner room is known as an access room (see 3.1).
3.49 fire safety policy
documented strategy that sets the standards of
3.58 integrity
fire safety that an organization is committed to ability of a separating element, when exposed to fire
maintaining on one side, to prevent the passage of flames and hot
NOTE For example, the starting point of a fire safety gases or the occurrence of flames on the unexposed
policy is expected to be that the organization complies side, for a stated period of time in a standard fire
with all legislative requirements in respect of fire safety. resistance test

3.50 fire safety refresher training 3.59 lifts


training given to employees periodically to ensure that 3.59.1 evacuation lift
they remain aware of the fire risks, fire prevention lift used as part of the evacuation sequence for persons
measures, fire protection measures and fire procedures with disability and persons requiring assistance, which
in the building has appropriate structural, electrical and fire protection
and is capable of being taken under control by a
3.51 fire scenario trained and authorized person

detailed description of conditions, including


environmental conditions, of one or more stages from
prior to ignition to after completion of combustion in
an actual fire at a specific location

6 © The British Standards Institution 2020


PAS 79-2:2020

3.59.2 fire-fighting lift 3.63 material alteration


lift which has protection, controls and signals which
alteration that changes (usually lowering or with the
enable it to be used under the exclusive control of the
potential to lower) the standard of fire protection
firefighters, but that are less stringent than those of a
originally provided
firefighters lift
NOTE Where the term “fire-fighting lift” is used in
this PAS, it refers to a lift installed in accordance
3.64 means of escape
with BS 5588-5, which was first published in 1986. structural means whereby a safe route for use in the
“Fire‑fighting lifts” were superseded by “firefighters event of fire is provided for persons to travel from any
lifts” with the publication of BS EN 81-72. point in a building to a place of ultimate safety without
external assistance
[SOURCE: BS 8899:2016, 3.6]
3.59.3 firefighters lift 3.65 non-combustible
lift which has protection, controls and signals which not capable of undergoing combustion under specified
enable it to be used under the exclusive control of the conditions
firefighters
NOTE Where the term “firefighters lift” is used in 3.66 non-maintained emergency lighting
this PAS, it refers to a lift installed in accordance with
BS EN 81-72, which was first published in 2003. lighting system in which all emergency lighting lamps
are illuminated only when the supply to the normal
[SOURCE: BS EN 81-72:2020, 3.5, modified – note added] lighting fails

3.59.4 firemen’s lift


3.67 occupant(s) especially at risk
lift installed before fire-fighting lift standards were
made available, incorporating only simple means to building occupant(s) who, as a result of their physical
recall the lift to a designated floor, with no complex or mental state, age or location in the building, are at
lift controls or protection measures for fire and rescue greater risk from fire than a non-disabled, fully alert
service use adult afforded adequate means of escape and other
NOTE 1 This is also known as a fire service lift. fire precautions, whether on a short-term or
long-term basis
NOTE 2 Where the term “firemen’s lift” is used in
this PAS, it refers to a lift installed in accordance
with BS 2655 or BS 5655 for use by the fire and 3.68 panic bolt
rescue service. “Firemen’s lifts” were superseded by mechanism, consisting of a minimum of two sliding
“fire‑fighting lifts” with the publication of BS 5588-5. bolt heads that engage with keepers in the surrounding
door frame or floor for securing a door when closed,
[SOURCE: BS 8899:2016, 3.8] which can be released by hand or body pressure on a
bar positioned horizontally across the inside face of
3.60 maintained emergency lighting the door
lighting system in which all emergency lighting lamps
are illuminated at all material times 3.69 panic latch
mechanism for securing a door when closed, with
3.61 mandatory sign a latch bolt that can be released by hand or body
pressure on a bar positioned horizontally across the
safety sign that indicates a specific course of action is to
inside face of the door
be taken

3.62 manual call point 3.70 peer-to-peer rented accommodation


accommodation rented by means of a decentralized
component of a fire detection and fire alarm system
platform whereby two individuals interact directly with
that is used for the manual initiation of a fire alarm
each other, without intermediation by a third party
signal
NOTE For the purposes of this PAS, the term
“peer‑to‑peer rented accommodation” includes letting
arranged through an agent.

© The British Standards Institution 2020 7


PAS 79-2:2020

3.71 person-centred fire risk assessment 3.78 refuge


(FRA) area that is both separated from a fire by fire-resisting
assessment of the risk from fire focused on a specific construction and provided with a safe route to a storey
resident, carried out with the involvement of the exit, thus constituting a temporarily safe space
resident, taking into account the physical and NOTE In Scotland, a refuge is generally known as a
cognitive characteristics of the resident, their lifestyle, “temporary waiting space” (TWS).
preferences and a contextualized consideration
of relevant behavioural history, which results in a
3.79 relevant fire safety legislation
proportionate person-centred action plan that takes
into account informed decision-making and dignity of legislation that sets out obligations relating to fire risk
the resident, while resulting in tolerable risk from fire assessment
NOTE The relevant legislation is:
3.72 phased evacuation • (in England and Wales) the Regulatory Reform
(Fire Safety) Order 2005 (as amended) [5];
system of evacuation in which different parts of the
building are evacuated in a controlled sequence of • (in Scotland) combination of the Fire (Scotland)
phases, those parts of the building expected to be at Act 2005 (as amended) [8] and the Fire Safety
greatest risk being evacuated first (Scotland) Regulations 2006 [9];
• (in Northern Ireland) the Fire and Rescue Services
3.73 place of relative safety (Northern Ireland) Order 2006 [13], together with the
Fire Safety Regulations (Northern Ireland) 2010 [14].
place in which there is no immediate danger, but in
which there could be future danger, from fire or the
effects of fire
3.80 required safe escape time (RSET)
time from ignition until the time at which all the
3.74 place of ultimate safety occupants of a building, or a specified part of a
building, are able to reach a place of safety
place in which there is no immediate or future danger
from fire or the effects of fire
3.81 safe condition sign
3.75 pre-occupation fire safety safety sign that indicates an evacuation route, the
location of safety equipment or a safety facility, or a
assessment safety action
process of identifying fire precautions in a newly NOTE A fire exit sign is an example of a safe condition
constructed or refurbished building, taking into sign.
account the approved fire strategy, and deciding
whether or not the new or refurbished premises are
likely to be fit for occupation
3.82 shared house
NOTE A pre-occupation fire safety assessment is not to type of house in multiple occupation, normally let to an
be confused with the fire risk assessment required by identifiable group, such as students, work colleagues or
fire safety legislation and described in this PAS, which friends, in which there is a significant degree of social
can only properly be carried out after a building has interaction
been handed over to the end user.
3.83 sheltered housing
3.76 products of combustion housing in which each dwelling is designed and
solid, liquid and gaseous materials resulting from constructed for the purpose of providing self-contained
combustion residential accommodation for older people, and where
some form of assistance is available at all times, though
not necessarily from persons on the premises
3.77 protected
NOTE This includes premises sometimes described
enclosed in fire-resisting construction as retirement housing and similar blocks of flats,
regardless of whether flats are rented or are leasehold.

8 © The British Standards Institution 2020


PAS 79-2:2020

3.84 short-term letting 3.89 stay put strategy


residential tenancy, of less than six months, of a fully strategy normally adopted in blocks of flats and
furnished property, where utilities and, normally, maisonettes whereby, when a fire occurs in a flat or
television and internet are included in the rent maisonette, the occupants of that dwelling evacuate,
NOTE For the purposes of this PAS, the term but occupants of all other dwellings can safely remain
“short-term letting” includes peer-to-peer rented in their dwellings unless directly affected by heat and
accommodation (3.70).The term of rental might be as smoke or directed to leave by the fire and rescue service
short as one night. NOTE In a building with a stay put strategy, all residents
are always free to leave their flats if they wish to do
3.85 simultaneous evacuation so (e.g. if they feel unsafe), but to do so might, under
some circumstances, place them at greater risk than
system of evacuation in which an entire building is remaining within their flats.
evacuated immediately on receiving an evacuation
signal (e.g. from a fire detection and fire alarm system)
or an evacuation alert signal from an evacuation alert
3.90 structural fire protection
system for use by the fire and rescue service (see 3.22), features in layout and/or construction that are intended
or an instruction to evacuate (e.g. given verbally to the to reduce the effects of a fire
residents of each dwelling by firefighters)
3.91 supported housing
3.86 smoke alarm housing (excluding sheltered housing and extra care
device containing within one housing all the housing) designed for vulnerable people with common
components, except possibly the energy source, characteristics, living as part of a community with
necessary for detecting smoke and for giving an audible support that is normally, but not necessarily, provided
alarm on a 24 h basis
NOTE 1 Smoke alarms can also give a visual alarm. NOTE This includes housing for groups of people
NOTE 2 The term “smoke alarm” is normally reserved with learning or physical disabilities and mental
for devices intended for domestic use. health issues, but not “hostel”-type accommodation
for groups such as homeless people, victims of
domestic violence or ex-offenders. Residents can live
3.87 specialized housing independently or as a single group.
accommodation for occupants who live independently,
or with an element of support, and who are wholly or 3.92 third-party fire risk assessor
mainly limited to a specific section of the population
and are likely to require additional measures to secure independent fire risk assessor, who is not an employee
their safety in the event of fire, including, but not of the dutyholder, but who is contracted to carry out
limited to, accommodation provided for older people, a fire risk assessment on behalf of a dutyholder on
physically disabled people, people with cognitive whom legislation imposes a requirement for a fire risk
difficulties and people with mental health issues assessment
NOTE A fire safety consultant is an example of a
3.88 sprinkler system third-party fire risk assessor.

system comprising thermosensitive devices designed to


react at a predetermined temperature by automatically
3.93 tolerable level
releasing a stream of water and distributing it in a <of fire risk> level at, or close to, that acceptable to a
specified pattern and quantity over a designated area dutyholder, taking into account the requirements of
fire safety legislation, the nature of the premises, the
fire hazards in the premises (see 3.31), the nature of the
occupants, the cost of additional fire precautions and
any other relevant factors

© The British Standards Institution 2020 9


PAS 79-2:2020

3.94 travel distance for means of escape and fire detection (usually by
means of smoke alarms) within at least a sample of the
actual distance to be travelled by a person from any flats; within the flats, the inspection is non-intrusive,
point within the floor area to the nearest storey exit, but the fire resistance of doors to rooms is taken into
having regard to the layout of walls, partitions and account
fixings
NOTE 1 A Type 3 fire risk assessment does not take into
account measures to prevent fire unless the measures
3.95 Type 1 fire risk assessment are within the control of the person on whose behalf
fire risk assessment for a block of flats, sheltered the fire risk assessment is being carried out.
housing or extra care housing, in which the scope of NOTE 2 A Type 3 fire risk assessment might be
the fire risk assessment is limited to common parts, appropriate for rented flats if there is a reason to
plant rooms and other non-domestic areas of the suspect serious risk to residents in the event of a fire in
building (if any), and in which the inspection of the their own flats.
building is non-intrusive NOTE 3 A Type 3 fire risk assessment is commonly
NOTE 1 In England and Wales, a Type 1 fire risk impossible to carry out in the case of long leasehold
assessment is the basic fire risk assessment required for flats, as there is normally no right of access for
the purpose of satisfying the Fire Safety Order [5]. freeholders or other parties for whom the Type 1 fire
NOTE 2 Although a Type 1 fire risk assessment is limited risk assessment is carried out.
in scope primarily to common parts of blocks of flats,
sheltered housing and extra care housing, inspection 3.98 Type 4 fire risk assessment
of the building includes examination of at least a
fire risk assessment that involves the same scope of
sample of flat entrance doors and reasonably accessible
work as a Type 3 fire risk assessment, except that there
service risers. Consideration also needs to be given to
is a degree of intrusive inspection, in both the common
external wall construction, though this might require a
parts and the flats, carried out on a sampling basis
fire risk appraisal and assessment by another specialist,
unless, for example, the wall is of traditional masonry NOTE 1 A Type 4 fire risk assessment is normally
construction. appropriate only in limited circumstances, such as when
a new landlord takes over a block of flats in which the
NOTE 3 The action plan of a Type 1 fire risk assessment
history of works carried out is unknown and there is
(see 3.2) might include a recommendation for a Type 2,
reason to suspect serious risk to residents from both a
Type 3 or Type 4 fire risk assessment to be carried out
fire in their own flats and a fire in neighbours’ flats.
(e.g. if the Type 1 FRA identifies cause for concern that
justifies intrusive inspection and/or consideration of fire NOTE 2 The nature of the work involved in a Type 4 fire
safety within flats). risk assessment is such that intrusive inspection within
flats can often be carried out only in vacant flats.

3.96 Type 2 fire risk assessment NOTE 3 The work of opening up and making good is
normally carried out by a contractor, rather than the
fire risk assessment that is generally similar, in scope fire risk assessor.
and objectives, to a Type 1 fire risk assessment, except
that there is a degree of intrusive inspection, involving
opening up of construction on a sampling basis and
3.99 water mist system
making good after the inspection distribution system connected to a water supply, with
NOTE 1 A Type 2 fire risk assessment is usually a one- atomizing media where required, that is fitted with
off exercise, which is carried out only if there is good one or more nozzles capable of delivering water mist
reason to suspect serious structural deficiencies that intended to control, suppress or extinguish fire
could lead to spread of fire beyond the flat of fire NOTE Water mist systems can discharge water or a
origin. mixture of water and some other agent or agents,
NOTE 2 The work of opening up and making good is e.g. inert gases or additives.
normally carried out by a contractor, rather than the
fire risk assessor. 3.100 wet fire main
water supply pipe installed in a building for firefighting
3.97 Type 3 fire risk assessment purposes and permanently charged with water from a
fire risk assessment that includes all work within the pressurized supply, fitted with landing valves at specific
scope of a Type 1 fire risk assessment, and so is non- points
intrusive, but also takes into account the arrangements

10 © The British Standards Institution 2020


PAS 79-2:2020

4 The concepts of fire risk and fire hazard

COMMENTARY ON CLAUSE 4 4.1 In the FRA, there should be a clear distinction


between the concepts of fire hazard and fire risk.
It is important that, in the fire risk assessment (FRA),
confusion does not result from loose, inexact or 4.2 In the FRA, the terms “fire hazard” and “fire
conflicting use of terminology. Particular care needs risk” should be used only in a context consistent with
to be taken to avoid improper use of the terms definitions 3.31 and 3.39.
“fire hazard” (see 3.31) and “fire risk” (see 3.39).
BS 4422:2005 defines a fire hazard as potential for 4.3 In documenting the significant findings of the FRA
injury and/or damage from fire. In the field of health (see Clause 10), there should be distinct, and separate,
and safety, a hazard is often defined as a source, consideration of fire hazards, situations and measures
situation or act with a potential for harm in terms of that affect the consequences of fire, such as fire
human injury or ill health, or a combination of these. protection measures (see 3.37), and the overall fire risk.
In this PAS, a fire hazard is defined as a source,
situation or act with potential to result in a fire.
Thus, the presence of uncontrolled fire hazards affects
the likelihood of fire, rather than the consequences
of fire. This is consistent with both BS 4422 and the
concept of hazard in the field of health and safety.

BS 4422:2005 defines fire risk as the product of the


probability of occurrence of a fire to be expected in a
given technical operation or state, and the consequence
or extent of damage to be expected on the occurrence
of fire. Accordingly, for the purpose of this PAS, fire
risk is defined as the combination of the likelihood
of the occurrence of fire and consequence(s) (number
and severity of injuries) likely to be caused by a fire.
This, again, is consistent with the broader concept of
risk in the field of general health and safety.

This clear distinction between fire hazard and fire risk is


of great value in any analytical approach to fire safety,
but particularly in an FRA. As stated above, fire risk is
the product of multiplying the probability of fire by a
measure of the consequences of fire if it does occur.
Thus, for example, even though the likelihood of fire
occurring might be low, the fire risk could still be high
as a result of potential for serious injury to occupants
in the event of fire. For example, the potential for
serious injury could result from inadequate provision of
fire exits and/or inadequate means of giving warning
to people in the event of fire. Such circumstances
would be likely to be regarded intuitively, even by a
lay person, as high risk, and accordingly this definition
of fire risk is likely to be relatively intuitive even to
non‑fire specialists.

© The British Standards Institution 2020 11


PAS 79-2:2020

5 Principles and scope of fire risk assessments

COMMENTARY ON CLAUSE 5 The FRA needs to involve a genuine and open-minded


approach to the assessment of fire risk and fire
The FRA is a systematic and structured assessment precautions. It is not, for example, appropriate to use
of the fire risk (see Clause 4) in the premises for the the FRA to justify a decision regarding fire precautions
purpose of expressing its current level, determining that has already been made without due consideration
the adequacy of existing fire precautions (see 3.34) and of risk, or to justify significant departures from
determining the need for, and nature of, any additional universally recognized industry good practice (e.g. the
fire precautions. Any such additional fire precautions frequency of testing and maintenance of fire protection
required are set out in the action plan (see 3.2), which systems recommended in relevant British Standards).
forms part of the documented FRA (see Clause 10).
The objective of the action plan is to set out measures It follows from the definition of fire risk that the FRA
that will ensure that the fire risk is reduced to, or involves consideration of relevant fire hazards and
maintained at, a tolerable level (see 3.93). the means for their elimination or control, i.e. fire
prevention measures. This contrasts with the approach
The FRA is not any of the following: adopted in now repealed fire safety legislation, which
a) a full audit of areas of the building that are not tended to concentrate on fire protection measures
readily accessible or visually obvious (e.g. roof voids (see 3.37), rather than fire prevention measures
and service risers), though a sample inspection of (see 3.35).
such areas is normally appropriate;
This approach to fire risk assessment tends to parallel
NOTE 1 A degree of sampling is particularly
that adopted in health and safety risk assessments,
important if the evacuation strategy is predicated
whereby the objective of the risk assessment is not
on a high standard of compartmentation (e.g. in
limited to merely preventing harm to people as a result
the case of a “stay put” strategy in a block of flats).
of a hazard, but begins with endeavours to eliminate
b) a means for verifying compliance with current or reduce the hazard itself. Thus, the FRA begins with
building regulations; endeavours to reduce the likelihood of fire. In this
c) a disabled access audit; sense alone, fire risk assessment is a more holistic
approach to the control of fire risk than that adopted
d) a means for identifying latent defects in
under 20th century fire safety legislation.
construction or compartmentation (see 3.13);
e) a means for verifying that the fire resistance of The likelihood of fire is rarely reduced to zero.
structural elements of the building is adequate; Accordingly, there is normally need for fire protection
f) an examination of the potential for structural measures, such as means of escape (see 3.64), measures
collapse of the building in the event of fire; that assist in the use of escape routes (see 3.21), means
g) a fire strategy report; of giving warning of fire (though in modern blocks of
flats this is limited to smoke alarms within individual
h) a pre-occupation fire safety assessment (see 3.75);
flats, as communal fire alarm systems are inappropriate)
i) a means for snagging of new construction; and means for fighting fire. However, these fire
j) a guide to legislation for the responsible person; or protection measures, by definition, only have a bearing
k) a fire risk appraisal and assessment of external wall on fire safety after fire has occurred and, therefore, fire
construction and cladding. prevention has failed.
NOTE 2 PAS 9980, which is in the course of
preparation at the time of publication of this
current PAS, will provide recommendations for a
fire risk appraisal and assessment (an “FRAA”) of
external wall construction and cladding of blocks
of flats.
NOTE 3 A standard scope of services, suitable for use
in a contract between a responsible person and a
fire risk assessor, is published by the Fire Industry
Association [17].

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PAS 79-2:2020

Most of the visible fire precautions in premises are Notwithstanding the above, on completion of a
fire protection measures, and it is with these measures new building, or of major refurbishments, major
and structural fire precautions that the fire safety alterations, etc., there can be benefit in carrying out
provisions within building regulations are primarily a “pre-occupation fire safety assessment” (see 3.75).
concerned. However, in modern premises, the risk to Pre‑occupation fire safety assessments are carried out
people (and property) from fire is often governed more if the end user wants to establish that the construction
by the quality of fire safety management (see 3.45) stage of the building has been completed, the fire
than the level of fire protection. In housing, it is rare strategy has been implemented correctly, and the
for any fire to result in deaths beyond a dwelling of necessary fire safety design measures have been
fire origin. Nevertheless, where such deaths occur, incorporated, prior to handover and subsequent
experience shows that a significant factor is commonly occupation. This information is usually communicated
a combination of a failure in fire safety management in the findings of a pre-occupation fire safety
at an organizational level, including management assessment. It is important that a pre-occupation fire
of alterations to the building, and inadequate fire safety assessment is not confused with the FRA to
precautions. which this PAS refers; the former is undertaken simply
to ensure a smooth transition from the design and
Thus, in contrast with the approach to compliance construction phase to the operational phase of new or
with building regulations, it is absolutely essential refurbished premises. However, even a pre-occupation
that every FRA gives thorough attention to fire safety fire safety assessment does not necessarily identify
management and, therefore, to matters such as the fire latent defects in construction.
strategy for the premises, fire procedures [including
their dissemination to residents, regardless of whether The fire prevention measures, fire protection measures
the evacuation strategy is “stay put” (see 3.89) or and components of fire safety management can be
simultaneous evacuation (see 3.85)], training of any treated as variables, the standard of which can be
staff in the premises, testing and maintenance of fire reduced or increased, according to the fire risk, in
protection equipment, inspection of means of escape, order to provide an integrated package of measures
control over alterations, control of work by contractors, that limits fire risk to a tolerable level. However, some
etc. Good fire safety management also contributes to factors that have a major impact on fire risk are not
the prevention of fire by incorporating policies and variable, but are “given” factors for the premises in
measures that reduce the likelihood of fire. question. Usually, basic information on such factors
can be treated as significant findings of the FRA, and
It follows, therefore, that the FRA can only validly be accordingly, such information needs to be recorded.
carried out on premises that are in use, so that the
actual working conditions, practices and procedures Such factors include, but are not limited to:
can be taken into account. The FRA required by the 1) the height of the premises (e.g. single storey or
relevant fire safety legislation (see 3.79), to which this multi-storey, low-rise or high-rise, the presence of
PAS refers, cannot be carried out at the design stage basements);
of new premises, nor is it a means for snagging, or
2) the construction of the premises [e.g. largely
verifying the adequacy of, fire precautions in newly
non-combustible (see 3.65) or mainly combustible
constructed premises prior to occupation. Parts of the
(see 3.12), timber-framed or modern methods of
FRA can be used for such a purpose, in order to review
construction];
fire protection measures at the design stage, and to
assist in ensuring that the premises, once constructed, 3) the complexity of the premises (e.g. simple,
are adequately safe from fire for occupation, but straightforward escape routes, with a single stairway
such an exercise would not constitute a suitable and for means of escape from upper floors, or complex,
sufficient FRA, as management issues and operational convoluted internal layout with multiple stairways);
issues cannot be properly addressed. 4) the approximate floor area of the premises;
NOTE 4 This does not imply that there is no need for an 5) the maximum number of occupants of the
FRA for vacant premises. For example, when premises premises;
become vacant for any period during the life of the 6) the maximum number of residents likely to be
building, they are not excluded from the scope of fire present;
safety legislation.
NOTE 5 It is acknowledged that, in general needs
blocks of flats, it is difficult to ascertain these
numbers with any degree of accuracy.

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PAS 79-2:2020

7) the nature of the occupants for whom the premises be considered separately in the FRA (see Figure 1).
are specifically designed (e.g. young or old, For example, in properly designed, constructed and
disabled or able-bodied); maintained single-storey premises with able-bodied
8) the familiarity of the occupants with the premises residents and an abundance of readily available fire
(e.g. normally fully familiar, unless the premises are exits, a fire might have less serious consequences
designed specifically for short-term residents); to occupants (in terms of injury) than in the case of
multi-storey premises with a predominance of disabled
9) the history of fires on the premises; and
people and poor compartmentation.
10) the incidence of malicious fire raising and
vandalism in the surrounding areas. On the other hand, in a high-rise block of flats with
Although the above factors cannot (or cannot readily) well-designed escape routes and a good standard
be changed, their effect on fire risk (primarily as a of compartmentation, if there is a significant build-
result of their effect on the consequences of a fire) up of combustible materials in the common parts,
needs to be taken into account in the FRA, so that the consequences to occupants in the event of fire
they are reflected in the level of fire risk expressed in in the common parts could be serious. Equally, in
the FRA. The level of fire precautions then needs to be each of these examples, poor standards of fire safety
proportionate to the level of risk. management could affect both the probability of fire
and the consequences of fire.
Since the likelihood (i.e. probability) of fire and the
consequences of fire, if it does occur, are largely
independent factors (see Clause 4), they need to

Figure 1 – Schematic of fire risk assessment process

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PAS 79-2:2020

Once the level of fire risk is determined, any need for The action plan (see Clause 19) needs to contain
improvements in fire precautions can be identified. measures that are reasonably practicable, risk-
The separate consideration of probability of fire and proportionate and normally prioritized, while resulting
consequences of fire is then of value, since, if the fire in compliance with legislation and the organization’s
risk is unacceptably high, the source(s) of the high fire fire safety policy (see 3.49). The nature of the measures
risk can be identified by separating the fire risk into specified needs to be such that they are likely to receive
its two component factors. It can then be determined acceptance by management and residents who might
whether the problem is primarily one of high likelihood be affected by them.
of fire, necessitating fire prevention measures in the
action plan, or serious consequences in the event 5.1 As a general rule, the FRA should be carried out
of fire, necessitating fire protection measures, or a only when the premises are in normal use. If, in the
combination of the two. case of new or refurbished premises, there is a need to
carry out an FRA before the premises are fully occupied
The determination of the likelihood of fire, the and in normal use, a further FRA should be carried out
consequences of fire, and hence the fire risk, can soon after the premises are in normal use.
normally be subjective in nature, and is not normally NOTE Where any premises stand unoccupied, the
quantified numerically. Numeric methods, including dutyholder still has a responsibility, under the relevant
calculation of probabilities and use of fire scenarios fire safety legislation, to ensure that an FRA is carried
(see 3.51), are not necessary or appropriate in the out.
case of an FRA for housing premises, other than in the
formulation of designs based on complex fire safety 5.2 Every documented FRA should explicitly set out
engineering (see 3.43). Moreover, care is necessary the significant findings of the assessment, including
to ensure that simple points schemes, which purport information on the scope and type of the FRA.
to evaluate fire risk numerically, are not misleading
(see Clause 18). It is very difficult in such schemes to 5.3 Within every documented FRA, it should be clear
allocate appropriate and proportionate weightings to that appropriate consideration has been given to the
different factors, and it is difficult to take into account following matters, regarding which there should be, at
the synergistic relationship between various, at first least, basic information and, where relevant, comment:
sight independent fire precautions and effects thereof. a) occupants and potential occupants;

Equally, if significant capital expenditure on fire b) fire hazards and means for their elimination or their
precautions is recommended in the action plan control;
(see 3.2), it needs to be possible to justify the c) relevant fire protection measures (see 3.37) and the
expenditure by articulation of a realistic and credible arrangements for relevant inspection, testing or
scenario, in which unacceptable fire risk to occupants maintenance of these measures;
would occur. In such cases, it is not, for example, d) relevant aspects of fire safety management; and
acceptable simply to justify significant capital e) any fire strategy adopted within the premises as
expenditure on the basis of a departure from current part of a fire engineering solution, or alternative to
guidance or practice, particularly in the case of premises prescriptive codes of practice for compliance with
designed and constructed prior to the introduction of building regulations, such as special managerial
such guidance or practice. arrangements.

Where, originally, the premises have been designed by 5.4 Every documented FRA should contain an
a competent fire engineer on the basis of fire safety expression of the level of fire risk, determined from the
engineering, and have been approved under relevant information recommended in 5.2 and 5.3.
building regulations, it is not generally necessary to
NOTE The level of fire risk may normally be expressed
check this design from first principles in the course of
subjectively (e.g. trivial, tolerable, moderate,
the FRA. It is, however, necessary to verify that features
substantial, intolerable).
and facilities that form part of the design are being
properly maintained and managed.
5.5 Every documented FRA should contain an action
plan (see Clause 19), unless it is expressly confirmed
within the FRA that no additional fire precautions
are necessary.

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PAS 79-2:2020

6 Responsibility for adequacy of the fire risk assessment

COMMENTARY ON CLAUSE 6 It is important that any person on whom the duty


to carry out an FRA is imposed understands and
Regardless of whether the FRA is carried out by, for acknowledges their responsibility for the FRA. While
example, staff of an organization, or by a third-party they can use the services of a third party to carry out
fire risk assessor (see 3.92), the ultimate responsibility the FRA, the ultimate responsibility for the adequacy
for the adequacy of the FRA rests with a dutyholder of the FRA cannot be delegated, making it important
(see 3.18), namely the person defined by legislation as that dutyholders satisfy themselves regarding the
responsible for ensuring that the FRA is carried out and competence of the fire risk assessors (see Clause 7).
that the fire precautions are adequate. Freeholders and managing agents in England and
Wales have been prosecuted for failures to ensure that
If persons are employed to work in the premises a suitable and sufficient FRA has been carried out, in
(e.g. a concierge in a block of flats, or care and support some cases in conjunction with the third-party fire risk
staff in supported housing), one dutyholder is their assessor with whom they contracted to carry out the
employer. However, in housing in which staff are not FRA, and, in other cases, without any legal proceedings
employed, the duty to carry out an FRA rests with the against the fire risk assessors.
person who has control of the premises. For example,
this can be (and typically is) the landlord, freeholder Where, within an organization, there is a competent
or the managing agents. Even if staff are employed to person (see 3.14 and Clause 7) able to carry out the FRA,
work in the premises, their employer might not be the it is appropriate for that person to carry out, or oversee
sole dutyholder; other persons having control of the any third party that carries out, the organization’s
premises, such as a landlord or managing agents, might FRAs. If FRAs are carried out by a third party, such as
have duties under the relevant fire safety legislation if, a consultant, it is essential that the organization for
under a contract or tenancy, they have responsibilities whom the FRA is carried out understands the role of
for maintenance of the premises, or certain of its fire the third party and the resulting FRA; the role is to
precautions, or the safety of the premises. For example, facilitate the FRA and to advise on fire precautions, but,
in some supported housing, the service provider might as noted above, the responsibility for the adequacy of
need to carry out an FRA to address the safety of staff the FRA and the adequacy of fire precautions rests with
and residents, but a landlord might also need to carry the organization.
out an FRA to verify the adequacy of fire precautions
for which they are responsible under a lease. It is also Notwithstanding the above, if a third-party fire risk
necessary to ensure adequate cooperation amongst assessor (such as a consultant) carries out an FRA that
dutyholders to verify that, jointly, they coordinate the is, subsequently, deemed (e.g. by a court) to have been
measures required to satisfy legislation. inadequate at the time it was carried out, such as to,
thereafter, place occupants of the premises at risk of
Where legislation imposes a requirement on any serious injury or death in the event of fire, the fire
dutyholder for an FRA to be carried out, it needs to risk assessor might then be exposed to civil or criminal
be clearly understood by the dutyholder that the liability. This is because, if, under a contract, a person
responsibility for the adequacy and accuracy of the has responsibility for the safety of premises, they can
FRA, and of the information contained therein, rests be regarded as “a person having control of the
with that dutyholder, rather than with the fire risk premises”, on whom the relevant fire safety legislation
assessor (see 3.41), regardless of whether the fire risk imposes duties in respect of the FRA. This situation
assessor is an employee of the organization or a third might, for example, arise if the fire risk assessor
party (e.g. a consultant). However, there is also a legal were seriously negligent in the scope of the matters
responsibility on the part of the fire risk assessor in considered in the FRA, their endeavour to obtain
contract law; criminal responsibility can also arise on relevant information, or their examination of fire
the part of the fire risk assessor under the relevant fire precautions (including managerial issues, such as
safety legislation if the FRA carried out by the fire risk dissemination of the evacuation strategy to residents,
assessor is inadequate to such an extent that one or and the arrangements of testing and maintenance
more relevant persons are, consequently, exposed to of fire protection measures). Equally, it is not
the risk of death or serious injury in the event of fire. expected that, in all FRAs to which this PAS applies,

16 © The British Standards Institution 2020


PAS 79-2:2020

intrusive investigations of structural fire precautions Where practicable, to ensure acceptance of the action
(e.g. involving opening up of the structure or removal plan, the recommendations in the action plan need,
of a section of ceiling) are carried out, nor is it in the course of the FRA, to be discussed with the
expected that any FRA will involve testing of active management of the premises in question to ensure that
fire protection measures (see 3.37) (see also Clause 15). the documented FRA is delivered to the appropriate
However, where doubt exists as to the adequacy of person(s), namely the person(s) on whom the findings
structural fire precautions, either through material impact and who can arrange for implementation of
changes to the building over time, or due to its age the action plan. The “ownership” of the FRA by the
and historical nature, it might be necessary to make dutyholder will then continue throughout the life of
a recommendation for an in-depth assessment of the premises, so that, for example, the FRA is subject to
compartmentation, which might be by other specialists. review at an appropriate frequency and when changes
take place (see Clause 20).
Where the FRA is carried out for an organization by a
third party, it is essential that the organization commits The FRA constitutes an underpinning for an
itself to the FRA from the outset. This means that organization’s compliance with fire safety legislation
the organization needs to provide information and and its own fire safety policy. It is essential that the
support for whoever carries out the FRA, as much of organization does not treat the FRA as a mere formality
the essential information required in order to carry out or “tick box” exercise, nor treat the documented FRA as
the FRA will reside within the organization and cannot a formal document that is an end in itself and is simply
be obtained by a third party without the organization’s stored away until the fire and rescue authority request
cooperation. The organization also needs to give sight of it.
practical support to the fire risk assessor (see 3.41)
by ensuring that the fire risk assessor has access to 6.1 Where, within an organization, an employee of the
appropriate people from whom information is to be organization is competent to carry out the FRA, where
obtained and has sight of relevant documentation, practicable that person should carry out, or oversee any
and by facilitating access to all areas of the premises, third party that carries out, the organization’s FRA.
including, for example, locked service risers and plant
rooms. It is also necessary, for example, in the case of a 6.2 The dutyholder should take all reasonable steps
block of flats, for the dutyholder to arrange access, so to ensure that every fire risk assessor who carries out
far as is practicable, to a sample of residents’ flats to, FRAs on their behalf is competent to carry out this
at least, carry out a check of the flat entrance doors; it task, regardless of whether the fire risk assessor is an
might also be necessary to check other matters, such as employee of the dutyholder or a third party, such as a
whether there is a common air extract system serving consultant (see Clause 7).
multiple flats.
6.3 The dutyholder should ensure that, to the extent
It is acknowledged that all relevant information is not possible (see 6.5), the fire risk assessor has access to
always readily available (e.g. because of the history appropriate people and relevant documentation, is
of old blocks of flats, ownership and management provided with all relevant information and has access
of which might have changed many times since the to all areas of the relevant premises, or part(s) of the
construction of the block). Also, access to all relevant premises, at the time of the FRA.
areas might be difficult to facilitate at the time of NOTE This includes access to certain locked areas, such
the FRA. While by means of, for example, pre-survey as plant rooms and at least a sample of service risers.
questionnaires, information can be researched by
dutyholders in advance of the FRA, the documented 6.4 In the case of a block of flats, the dutyholder should
FRA might need to recommend further investigation arrange access to a suitably representative sample of
of relevant information by the dutyholder, or flats to check certain matters, such as the adequacy
recommend that the dutyholder carries out their own of the flat entrance doorset, and to verify whether a
check of areas to which access was not available at the common air extract system serves multiple flats. Where
time of the FRA. practicable, access should also be arranged to at least
a sample of any roof voids. In the case of flat entrance
doorsets, a representative sample of door archetypes
should be checked.

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PAS 79-2:2020

6.5 If adequate information and access cannot be


provided at the time of the FRA, the action plan should
identify further investigation or checking of areas to
be carried out subsequently by the dutyholder or a
competent person instructed by the dutyholder.

6.6 The dutyholder should ensure that the documented


FRA is studied carefully by appropriate people in the
organization to verify the accuracy of documented
information, to understand the contents, particularly
the fire hazards, fire safety measures and any
shortcomings in fire protection measures or fire safety
management, and to implement the action plan.

6.7 After the FRA has been carried out, it should be


subject to regular review, particularly when changes
that could affect fire risk occur or when there is any
other reason to suspect that the FRA is no longer valid
(see Clause 20).

18 © The British Standards Institution 2020


PAS 79-2:2020

7 Competence of fire risk assessors

COMMENTARY ON CLAUSE 7 b) an awareness of the limitations of the fire risk


assessor’s own experience and knowledge; and
The FRA, and its periodic review (see Clause 20), is a c) a willingness and ability to supplement existing
foundation for continued adequacy of fire precautions experience and knowledge, when necessary, by
on an ongoing basis, after compliance with building obtaining external help and advice.
regulations. It is, therefore, essential that FRAs are
only carried out by competent persons (see 3.14). Legal Higher risk or more complex premises require a higher
liability can arise on the part of the dutyholder and the level of knowledge and experience on the part of
fire risk assessor if an FRA is not suitable and sufficient. the fire risk assessor. For complex premises, there
If the inadequacy of the FRA puts one or more relevant is a need for the specific applied knowledge and
persons at risk of serious injury or death in the event skills of an appropriately qualified specialist. In such
of fire, an offence is committed by the dutyholder. cases, evidence of specialist training and experience,
The same offence could also be committed by the fire or membership of a professional body, can assist in
risk assessor. demonstrating competence. In this connection, risk is
not directly associated with, for example, the height of
At the time of publication of this PAS, the competence a building; a two-storey residential care home is likely
of fire risk assessors is under much scrutiny following to present a greater risk to occupants from fire than a
the Hackitt Review of building regulations and fire 20-storey block of flats. The fire at Grenfell Tower in
safety [18]. The Review recommended that enhanced London in 2017 is extremely anomalous in this respect;
competence is necessary to carry out an FRA for indeed, the largest loss of life in a single fire between
high‑risk residential buildings, though this assertion the fire at King’s Cross underground station in 1987 and
does not appear to be evidentially based. As a result the Grenfell Tower fire occurred at a residential care
of this, a new competence standard will be developed home in Lanarkshire in 2004. In the context of housing
by the Fire Sector Federation during the expected life within the scope of this PAS, because of residents’
of this PAS. It is important that users of this PAS make disabilities, a small supported living property can
themselves aware of developments in this respect. present a greater fire risk than a general needs tower
For fire risk assessors, this is necessary to avoid their block of flats.
FRAs being deemed inadequate, thereby leaving
occupants of buildings exposed to risk, and consequent Significant experience of inadequate FRAs, carried
liability for the fire risk assessor in both civil and out by those who are not competent to do so, has,
criminal law. For dutyholders, for the same reasons, since the introduction of current fire safety legislation
there is, as discussed in Clause 6, a need to ensure the in Great Britain in 2006, caused increasing concern
competence of those engaged by them to carry out amongst regulators, enforcing authorities and the fire
FRAs for which the dutyholder will, ultimately, safety profession. As a result, a “Fire Risk Assessment
be responsible. Competency Council” was formed in 2010 with
the objective of setting a competence standard for
Competence does not necessarily depend on the third‑party fire risk assessors, who carry out FRAs for
possession of specific qualifications, although such clients on a commercial basis. The Fire Risk Assessment
qualifications might contribute to the demonstration Competency Council comprised representatives from
of competence. In the case of small simple premises, central government, the then Chief Fire Officers’
where the fire risk assessor might, for example, be Association (CFOA) (now the National Fire Chiefs
a non-specialist employee of the dutyholder, it is Council), the professional bodies within the fire safety
possible that, provided the fire risk is relatively low, profession, relevant trade associations and other
the following attributes of the fire risk assessor might relevant stakeholders. In 2011, the Fire Risk Assessment
be sufficient in conjunction with a study of suitable Competency Council published their competence
guidance documents: standard for fire risk assessors6). The intention was
a) an understanding of relevant current best fire safety that this standard would provide a basis for consistent
practices in premises of the type in question; evaluation of the competence of fire risk assessors

6)
Available at http://www.cfoa.org.uk/19532

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PAS 79-2:2020

by those professional bodies engaged in registration factors associated with occupants especially at risk
of competent fire risk assessors, and by third- within premises of the type in question;
party certification bodies that operate certification g) understand the causes of fire and means for their
schemes for fire risk assessors. As noted above, a new prevention;
competence standard will be published under the
h) understand the design principles of fire protection
auspices of the Fire Sector Federation.
measures relevant to the buildings being assessed;
The competence of fire risk assessors arises from i) have an understanding of critical management
a sound underpinning combination of education, arrangements, emergency and evacuation planning,
training, knowledge and experience in the principles and any relevant staff requirements for all
of fire safety. In this connection, education is likely occupancy types;
to involve formal education of a relatively academic NOTE 1 This is particularly critical for occupants
nature, often culminating in a qualification (although with vulnerabilities or dependencies that generate
not necessarily to degree level). Training involves a need for support, and the impact of that on
training of a practical nature, often given on the evacuation plans and staffing levels.
job. Knowledge can be obtained by academic study, j) have an understanding of evacuation strategies and
training, working alongside others, short courses, their application to buildings;
continuing professional development or
k) have a good appreciation of fire precautions in
any combination of two or more of these.
older existing buildings (e.g. such as early tower
blocks of flats or large houses that were converted
It is not implied that education, training and experience
into flats many years ago), as opposed to an
in the principles of fire safety need each be extensive,
understanding of only current standards under
provided that the combination of each results in
building regulations;
adequate knowledge. Moreover, a high level in respect
of any one of these might compensate for a lower level NOTE 2 Fire safety specialists experienced only in
in another. the design of new buildings might not necessarily
possess an appreciation of standards in buildings
A number of bodies maintain a register of persons constructed before current building regulations
who they consider competent to carry out FRAs. These came into force, nor of the extent to which such
include relevant professional bodies, and certification standards continue to be acceptable.
bodies accredited by UKAS to provide assessment and l) have a good understanding of domestic fire safety,
certification services. Registration of a fire risk assessor particularly in the case of Type 3 and Type 4 FRAs
on such a register can give confidence in the education, (see 3.97 and 3.98 respectively);
training and experience of the fire risk assessor to those m) have appropriate training and/or experience in
who wish to use the fire risk assessor’s services. carrying out FRAs; and
n) have evidence of continuing professional
7.1 All FRAs should be carried out by a competent
development that includes assimilation of lessons
person (see 3.14).
learned from past multiple fatality fires in housing.
7.2 The fire risk assessor need not possess any specific NOTE 3 At the time of publication of this PAS, there
academic qualifications, but should: are plans by the Government in England and Wales
a) understand the relevant fire safety legislation; to make changes to fire safety legislation. It is
important that fire risk assessors monitor, and react
b) have a thorough knowledge and understanding
to, changes in fire safety legislation as part of their
of government, and other, guidance document(s)
continuing professional development.
relevant to the premises in question;
c) have appropriate education, training, knowledge
and experience in the principles of fire safety;
d) have an understanding of fire development, the
response of building construction and materials to
fire and the behaviour of people in fire;
e) have an understanding of occupants especially at
risk from fire who are likely to be present in the
premises for which the FRA is carried out;
f) understand the fire hazards, fire risks and relevant

20 © The British Standards Institution 2020


PAS 79-2:2020

8 Benchmark standards for assessment


of fire precautions

COMMENTARY ON CLAUSE 8 In the case of fire protection measures, a plethora


of standards exist. For some specific fire protection
The assessment of fire precautions in the FRA does systems, a single, universally accepted standard exists
not merely involve rigid comparison of existing fire and is based on sound engineering principles. This
precautions with standards set out in prescriptive codes is the case in respect of, for example, fire detection
of practice. Similarly, the action plan is not based on and fire alarm installations (BS 5839-6) and automatic
rigid adherence to prescriptive norms found in codes sprinkler installations (BS 9251). These standards are
of practice. To adopt such an approach would not invariably adopted in the design of new installations
necessarily result in risk-proportionate fire precautions. within housing.

Nevertheless, in assessing or formulating measures to However, in many codes of practice, certain parameters,
eliminate or control fire hazards (see 3.31), it is often such as the illuminance levels of emergency escape
appropriate, in the case of certain fire hazards, such lighting, the fire resistance of flat entrance doors in
as potential electrical faults, to adopt guidance in blocks of flats and sheltered housing, and the trigger
recognized codes of practice. This is particularly the heights above which more onerous fire precautions are
case where these codes of practice are well established, specified, are acknowledged to be relatively arbitrary
universally recognized, produced by authoritative in nature. Thus, minor variations from numerically
bodies with specialist knowledge regarding the expressed limitations or performance levels need
hazard in question, and based on sound scientific not necessarily have any significant effect on fire
or engineering principles (as opposed to arbitrary risk. Nevertheless, where the action plan includes
judgements). The view of the Health and Safety recommendations for upgrading any aspect of fire
Executive is that it is not appropriate to use risk precautions (e.g. improvement in the illuminance
assessment to justify departures from practices that levels of an emergency escape lighting installation or
are universally accepted as appropriate within an replacement of a flat entrance door), it is appropriate
industry sector [19]. to adopt the relevant recommendations of the
appropriate current code of practice within the
Thus, for example, in considering the fire hazard action plan.
created by defective electrical wiring, it is normally
appropriate to control the hazard by inspection Traditionally, the design of various other fire protection
and testing of the fixed electrical installation in measures recommended within the relevant code
accordance with BS 7671 and with guidance produced of practice is often based more on custom and
on this subject by the Institution of Engineering and practice, and on arbitrary recommendations, than
Technology [20]. It is normally inappropriate for the fire on scientific and engineering principles. Moreover,
risk assessor to advocate control measures that conflict various conflicting recommendations often occur
with such guidance. within different codes of practice on the same
subject, such as those relating to structural fire
However, in the case of other fire hazards, such as protection (see 3.90). In addition, sometimes different
restrictions in combustible materials in common parts recommendations apply to new and existing premises.
of flats and sheltered housing, or use of portable For example, recommendations within guidance
heaters by residents in supported housing, the that supports building regulations often differ from
knowledge, experience and judgement of the fire risk recommendations within guidance that supports
assessor is much more important. Although there is legislation applicable to existing premises.
ample guidance on such matters in various publications, Typically, guidance on fire protection measures for
the guidance is less universally recognized, more new premises (e.g. guidance that supports building
general in nature and not exactly applicable in regulations) is more onerous than guidance on fire
every situation. precautions in existing premises (e.g. guidance that
supports the relevant fire safety legislation). This makes
rigid adherence to any particular code of practice even
less appropriate.

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PAS 79-2:2020

It also follows that use of guidance that supports However, although it has always been intended that
building regulations for the purposes of an FRA for codes of practice are simple benchmarks, in respect
existing premises, constructed before the introduction of which there is flexibility in application, there is
of the current building regulations, is inappropriate a perception (sometimes, but not always, correctly)
and would often result in an unduly harsh assessment that there has been inflexible application of codes
of risk in conjunction with an action plan that is not of practice. This has arguably tended to result in
risk-proportionate. This is an error sometimes found unnecessary restrictions on the design and use of
in FRAs and ought to be challenged by dutyholders if premises, and in over-extensive fire precautions.
encountered.
The “one size fits all” nature of prescriptive codes
A classic example of this concerns means of escape can also result in lower standards of fire protection
(see 3.64). Different maximum travel distances measures than warranted by the fire risk. An example
(see 3.94) are recommended in different codes of of this is the assumption within some codes of practice
practice dealing with different premises, and even in that fire precautions in certain forms of specialized
different codes of practice that can be applied to the housing need be no different from fire precautions in
same premises. Yet, travel distance is a fundamental general needs housing. However, the FRA might well
component in the design of means of escape. determine that there is a need for fire precautions in
such premises that would not be required in general
Nevertheless, for example, different maximum travel needs housing. Additionally, prescriptive standards
distances are given in different relevant codes of can become outdated, and fire protection measures
practice and guidance documents, such as BS 9991 designed in accordance with such standards might not
and government guidance throughout the UK on be sufficient. For example, in blocks of maisonettes,
compliance with building regulations. Similarly, within early design standards permitted link balconies, shared
government guidance, for example, on blocks of flats, by two maisonettes, as an alternative means of escape
the recommended fire resistance of flat entrance doors from the upper storey of each maisonette; this would
in high-rise blocks of flats in Scotland is 60 min, but is not now be acceptable, even in an existing block.
30 min elsewhere in the UK. Many similar variations
exist in the more detailed recommendations of various At the design stage of premises, the alternative
codes of practice; in some cases, these variations are to application of all recommendations within a
arbitrary in nature rather than based on fire safety prescriptive code of practice is the application of fire
engineering principles. safety engineering (see 3.43), usually in conjunction
with many, but not all, of the recommendations from
This has led to a school of thought amongst some the codes of practice. However, formulation of fire
experts that the application of prescriptive codes of protection measures from a first principles approach to
practice within the FRA is inappropriate. However, fire safety, for example using fire safety engineering, is
while there is a need for risk-proportionate fire complex, time consuming and demands the expertise
precautions, rather than rigid application of of specialists, such as a fire safety engineer (see 3.42).
prescriptive norms, prescriptive codes of practice have It is not usually an appropriate approach to the FRAs
achieved their objective; for example, it is rare for a required by legislation, albeit that the principles of
death from fire to occur beyond the dwelling unit fire safety engineering, applied subjectively, can be
in which fire occurs in buildings that conform to the relevant.
relevant code of practice.
For example, when fire occurs, a key factor in the safety
This might be as a result of the continual development of occupants is the required safe escape time (RSET)
of the well-established codes of practice over many (see 3.80). Control of maximum travel distance and
years, and of the fact that, when codes of practice have minimum exit widths, using the same figures for all
been found to be deficient following a serious multiple premises of the same purpose group, is an imprecise
fatality fire, the codes have been amended, or new way of ensuring that RSET is suitably limited, and only
codes have been developed, to address the deficiency. addresses the time between response of occupants to
Such developments in prescriptive codes of practice an alarm signal and the point at which they reach a
arguably result in a level of fire precautions that is place of relative safety (often described as “evacuation
sufficient to reduce fire risk to a tolerable level, and in time”). This approach ignores time for detection of
fire protection measures that are relatively forgiving in fire, the subsequent time interval before an alarm
the event of inadequate fire prevention measures and signal is given to occupants and the time for occupants
shortcomings in fire safety management. to recognize the alarm signal. Moreover, it takes no
account of the time for occupants to respond to the

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fire alarm signal (which can sometimes be longer than A subsequent Determination by the Secretary of State
the combination of all other time intervals and the in England noted that:
evacuation time).
“There is no requirement under the Fire Safety
However, calculation or prediction of these time Order for a Responsible Person to comply with
intervals is extremely difficult. Furthermore, a provisions relating to new buildings and alterations
knowledge of RSET in isolation is of little value. It is under the Building Regulations.”
more appropriate to compare RSET with the available
safe escape time (ASET) (see 3.6). 8.1 Assessment of fire precautions should take
into account guidance within relevant, recognized
This PAS is intended to be suitable for use by, for codes of practice, particularly those produced by
example, fire risk assessors with a background in the relevant government departments in support of
application or enforcement of traditional prescriptive the relevant fire safety legislation, albeit that rigid,
fire protection codes of practice. Accordingly, it is prescriptive application of these is not appropriate.
assumed that published guidance will be a starting While fire precautions recommended in the action
point or benchmark for assessment of the adequacy plan should also take account of such codes of practice,
of fire precautions in the premises. It is, however, the recommendations in the action plan should be
further assumed that the fire risk assessor is capable risk‑proportionate, which might necessitate measures
of exercising judgement to determine whether of a standard above or below that recommended in the
the recommendations of such guidance ought to relevant code of practice.
be relaxed, or added to, in order to determine the NOTE Different guidance documents apply to England
appropriate level of fire precautions and to formulate and Wales, Scotland and Northern Ireland.
a risk-proportionate action plan.
8.2 Departures from the recommendations of
Nevertheless, it is also expected that a competent fire recognized codes of practice should be based on the
risk assessor will not simply apply guidance and codes judgement of the fire risk assessor, and should take into
of practice “blindly”, without proper consideration of account relevant fire safety, or fire safety engineering,
the risk. Guidance on the relevant fire safety legislation principles, while adopting a pragmatic approach that is
makes it clear that the guidance is not intended to be based on assessment of risk.
applied prescriptively.
NOTE 1 It is of benefit, particularly to those who
subsequently audit the FRA, such as enforcing
In Scotland, a Determination by the Chief Inspector
authorities, if significant departures from recognized
of Fire and Rescue Authorities, in respect of a dispute
codes of practice, deemed acceptable by the fire risk
between a dutyholder and the enforcing authority, has
assessor, are recorded and justified in the documented
reinforced this point. Although such a Determination
FRA (see Clause 10). It is then clear that there has been
only applies to the specific case, the Determination in
appropriate consideration of the matter and that it has
question makes the following general points:
not simply been overlooked.
“While it is totally appropriate to compare existing NOTE 2 Departures from the recommendations of
fire safety measures against suitable benchmarks, recognized codes of practice might arise from a fire
using these benchmarks as prescriptive standards engineering solution described in the fire strategy for
is inappropriate. The benchmarks in the Scottish the building. An understanding of the fire strategy, if
Government’s guides are not meant to be available, is likely to be valuable in any FRA.
prescriptive or minimum standards to be applied.
This is stated in each guide and was specifically
reinforced in Scottish Fire and Rescue Service
Circular 17/2007 which says ‘the benchmarks in the
sector specific guides are not designed to be used
as prescriptive standards’.”

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PAS 79-2:2020

9 Assessment of premises design and fire precautions


that do not conform to current standards

COMMENTARY ON CLAUSE 9 In some cases, upgrading to current standards would,


NOTE This clause does not apply to new, or very in any case, not just fail to meet the test of reasonable
recently constructed, buildings in which there are practicability (see Clause 19); upgrading might be
defects in construction; the clause is limited to older architecturally impossible. For example, in England
buildings that were designed in accordance with and Wales, Approved Document B [21] advocates that,
previous standards, and so might not conform to in the design of a new block of flats with a single
current standards. staircase, the maximum travel distance between a flat
entrance door and a stairway ought not to exceed
Often, the design of a building for which an FRA is 7.5 m; in many older blocks of flats, the travel distance
to be carried out, and the design, or extent, of the is several times this figure and cannot normally be
fire precautions for the building, does not conform reduced. In rare cases (such as cross-ventilation within
to current standards as set out in either guidance for the common parts of blocks of flats), a previously
new premises (e.g. in England and Wales, Approved required measure that has been compromised
Document B [21]) or government guidance on by occupants is not now, in any case, regarded as
compliance with the relevant fire safety legislation. necessary, because a different design approach is now
adopted.
For example, there might have been significant changes
to guidance on means of escape since the building was It is an inherent part of the FRA process in such cases to
constructed; a common example of this is high-rise determine whether departures from current guidance,
blocks of flats constructed during the 1960s or 1970s. including guidance that supports the relevant fire
Alternatively, there might have been major changes safety legislation, create sufficient risk to warrant
in guidance on fire precautions in certain existing upgrading of fire precautions to current standards.
types of premises; for example, current guidance on Obviously, this involves subjective judgements, but a
fire precautions in supported housing recommends departure from prescriptive guidance is not, alone,
fire precautions that greatly exceed those previously sufficient justification for upgrading work.
regarded as acceptable.
Figure 2 is intended to assist in a logical approach
Guidance on the extent to which a fire protection in the case of older premises, constructed before
measure is provided might also have changed. Indeed, recognized current guidance was published. The first
it might even be the case that a fire protection system step is to determine whether the fire precautions satisfy
that is now required by legislation was not required the standards that were applicable at the time of
at the time that the building was constructed. For construction. This might bring to light original building
example, in Wales, for compliance with building defects. More likely, it might identify aspects in which,
regulations, it is recommended in government perhaps over many years, the originally required fire
guidance that all new dwellings (flats and houses) precautions have been compromised.
are sprinklered; this is also advocated in government
guidance for flats in blocks of flats over specified In such cases, the first measures that need to be
heights in Scotland and England. This would previously specified in the action plan are measures to restore
have been very uncommon. the conditions stipulated by the original standard.
An exception to this is where the original standard
It is not necessarily (and is often not) the case that is no longer applicable. For example, if, in a block of
failure to comply with current guidance necessitates flats in England or Wales, self-closing devices have
upgrading of fire precautions to meet current been removed from internal doors within the flats, it
standards, particularly those imposed in the design of might not be necessary to restore these, as Approved
new premises under building regulations. It is almost Document B [21] no longer advocates these as necessary
a truism that standards, in their development over a for compliance with current building regulations.
period of time, improve levels of safety, but this does
not necessarily imply that older standards are unsafe.

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The next step, having confirmed that the building practicable, it is appropriate to acknowledge the
met the provisions of the original standard (or having departure from current standards, so that, at some
recommended measures to restore those provisions), future time (e.g. when refurbishment takes place),
is to confirm whether the building would meet the current standard can be adopted.
the current standards. Sometimes, even when the
building was constructed before these standards were 9.1 In carrying out an FRA of premises constructed
introduced, fortuitously, the building does actually before the introduction of current standards, the fire
conform to current standards. risk assessor should have at least a basic understanding
of the standards that were applicable to the premises
The crux of the FRA process is often to determine at the time of construction.
whether departures from current standards create
unacceptable risk (i.e. whether the departure from 9.2 In formulating an action plan for the premises
current standards really matters to any degree). described in 9.1, the fire risk assessor should follow
Obviously, extremes exist in this respect. For example, as the logic set out in Figure 2. It should not be assumed
noted in the commentary on Clause 8, link balconies as that prescriptive application of current standards is
an alternative means of escape from the upper storey necessary, but, where the continued adoption of the
of a maisonette would not be acceptable today, even original standard is considered to create significant risk,
though this was acceptable in earlier standards for fire measures that are reasonably practicable should be
safety in blocks of maisonettes. recommended in the action plan (see Clause 19).
These should accord with either prescriptive or
On the other hand, in 1999, the level of illuminance performance-based standards and ultimately the
of emergency escape lighting on defined escape functional requirement.
routes, specified in the relevant British Standard, was
increased by a factor of five in the process of European
harmonization. The original level of illuminance of a
system installed prior to 1999 might remain acceptable
until a new system is installed, in which case the current
standard would be adopted.

Between these two extremes there are many “shades


of grey”. In making judgements, all the circumstances
of the case need to be taken into account. For example,
in the case of sheltered housing, where a significant
proportion of residents might be partially sighted, it
might be appropriate to upgrade an old emergency
escape lighting system to meet the current standards
of illuminance.

A common perplexity relates to the fitting of


intumescent strips and smoke seals to fire-resisting
doorsets that were manufactured or installed before
the strips and seals were considered necessary.
Again, extremes exist, requiring careful judgement
on reasonable practicability for all cases between
these extremes. In a block of flats in which all other
fire precautions are adequate, it is not normally
necessary to replace or upgrade original, well-fitting
flat entrance doors that satisfied the standards of fire
resistance applicable at the time the block of flats
was constructed. On the other hand, if the maximum
distance of travel from a flat entrance door to a
stairway is greatly excessive in the context of current
standards, it might be appropriate to upgrade, or even
replace, flat entrance doors, so that the doors afford
a fire resistance of 30 min and are fitted with smoke
seals. Sometimes, where upgrading is not reasonably

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PAS 79-2:2020

Figure 2 – Decision tree for action plan when existing premises do not conform to current
standards

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10 Documentation of fire risk assessments

COMMENTARY ON CLAUSE 10 One suitable format for documentation is given in


Annex A to this PAS. However, as there is evidence to
There is no single correct means of documenting an suggest that PAS 79 is becoming, to some extent, an
FRA, nor are there specific, definitive requirements industry standard, it needs to be noted that Annex A
within legislation for the content of a documented is informative, not normative. Accordingly, provided
FRA, only that the “significant findings” and any group that the recommendations in the PAS, including those
of occupants especially at risk be recorded. The fire risk within the normative annex, are followed, there will be
assessor therefore needs to make a judgement as to compliance with this PAS even if Annex A is not used.
what constitutes “significant findings” and “occupants
especially at risk”. For blocks of flats, sheltered housing and extra care
housing, this PAS recognizes four different types of
Clause 12 gives details of the information that needs FRA. For compliance with the relevant fire safety
to be taken into account in the FRA and the matters on legislation, a Type 1 FRA is nearly always sufficient;
which judgements need to be made. Such information only in unusual cases would a Type 2 FRA be necessary
needs to be documented, along with other relevant to satisfy legislation (e.g. where there is a basis for
factual information (e.g. managerial responsibility for serious concerns regarding compartmentation).
fire safety). In the case of certain matters, particularly In the documented FRA, there is a need for distinction
the “given” factors taken into account in assessment of between matters that are related to compliance
the fire risk (see Commentary on Clause 5), information with the relevant fire safety legislation and matters
about the factors (e.g. number of storeys of the that are outside the scope of the relevant fire safety
premises) needs to be recorded. legislation. It is particularly important for dutyholders
to understand whether recommendations in the action
In the case of other matters, such as certain fire plan are, in effect, legal requirements or whether they
protection measures (e.g. emergency escape lighting), go beyond the minimum requirements of legislation.
it might be sufficient to acknowledge that appropriate
consideration has been given to the matter (see 5.3), 10.1 A documented FRA should meet the
without necessarily recording, where relevant, more recommendations given in 5.2 to 5.5.
than a brief summary about its provision and location. NOTE Annex A contains a pro forma that is considered
Indeed, unnecessary detail might not be conducive to be a suitable and sufficient means for documenting
to ensuring that the appropriate person(s) studies the FRA. The pro forma contained in Annex A is only
the document properly or takes note of significant a model, in that, if completed by a competent person
findings. However, if, for example, the design of a fire (see Clause 7), the scope of the documented FRA will
precaution (e.g. means of escape) departs significantly normally conform to the recommendations of this
from a recognized norm, but the departure is PAS. Equally, the format of a documented FRA may
considered acceptable by the fire risk assessor, it is of vary from that shown in Annex A, provided that all
value to document the justification for this. It is also recommendations of this PAS are satisfied.
relevant to record measures that need to remain in
place to address specific risks or to compensate for 10.2 For persons known to be especially at risk,
shortcomings in other fire protection measures. sufficient information should be recorded about the
nature of that risk to enable verification as to whether
Since the purpose of an FRA is to lead to the safety measures to address the risk are in place [e.g. PEEPs
of occupants of the premises from fire, the important (see Commentary on Clause 15) and GEEPs or other fire
issues are the scope of the FRA, the competence with protection measures].
which relevant matters have been considered and the
NOTE 1 For example, it is not sufficient to record the
content of the documented significant findings.
presence of disabled people without some reference
The format of the record is then very much a secondary
to the nature of their disabilities; Deaf and hard of
consideration, although there needs to be evidence for
hearing people, for example, need different provisions
those who audit the FRA (e.g. an enforcing authority)
for their safety to persons with impaired mobility.
that the requirements of the relevant fire safety
This principle is particularly important in the case
legislation have been addressed when the FRA was
of premises in which the majority of occupants are
carried out. In this connection, objections to any specific
disabled people (e.g. extra care housing).
format are not legitimate.

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PAS 79-2:2020

NOTE 2 It is accepted that, in general needs housing


(e.g. a general needs block of flats), it is not normally
practicable for the FRA to identify residents with
disabilities.

10.3 In the case of a Type 3 or Type 4 FRA, there should


be a clear distinction between matters that have been
considered for the purpose of compliance with the
relevant fire safety legislation and matters that are
outside the scope of legislation. Within the action
plan, there should be a clear distinction between
recommendations that are considered necessary for
compliance with the relevant fire safety legislation and
recommendations that exceed the requirements of
relevant fire safety legislation.

10.4 If any fire protection measure obviously and


significantly departs from the standard recommended
in a relevant guidance document or prescriptive
code of practice, but no upgrading of the measure is
recommended in the action plan, the acceptance of
the existing standard should be justified within the
documented FRA.
NOTE The departures to which 10.4 refers are primarily
those affecting provisions for means of escape and
functional aspects of fire protection systems; it is
not, for example, intended that justification of the
continued use of a fire alarm system or emergency
escape lighting system designed in accordance with a
superseded standard would normally be necessary.

10.5 The FRA should record:


a) the name of the fire risk assessor(s) and any relevant
qualifications or certification that they hold;
b) the date(s) on which the FRA was carried out and
the date that the FRA was published;
c) the name(s) of the principal person(s) who was
consulted (e.g. for supply of relevant information)
at the time of the FRA; and
d) the name of the person (if any) who checked the
FRA report and any relevant qualifications or
certification that they hold.
NOTE This might be the same person who carried
out the FRA and who wrote the report, but it needs
to be made clear.

10.6 The FRA should record any significant areas of the


premises to which access was not possible at the time of
the FRA.

10.7 The FRA should record the date by which it is to be


subject to review (see Clause 20).

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11 Nine steps to fire risk assessment

COMMENTARY ON CLAUSE 11 b) The second step is fire hazard identification


(see 3.32) and the determination of existing
To promote a structured approach to fire risk measures for the elimination or control of the
assessment (see Clause 5), this clause sets out nine steps identified fire hazards. This normally involves a
in the FRA process, somewhat akin to the five steps to combination of interviewing the management and
risk assessment often adopted in a health and safety inspection of the premises.
risk assessment. Some guidance documents suggest c) The third step is to make a (subjective) assessment
five steps in an FRA; this PAS is consistent with such of the likelihood of fire. This is based primarily on
guidance, but breaks down the process into more the findings of step two (see Figure 1). However,
detail. The number of steps defined is irrelevant; the the assessment of the likelihood of fire also takes
important matter is that an appropriately structured into account any relevant information obtained in
approach is adopted and that all relevant issues are step one.
addressed.
d) The fourth step is to determine the physical fire
a) The first step is to obtain relevant information about protection measures (see 3.37) relevant to the
the premises and the occupants of the premises. protection of people in the event of fire.
Where persons present in the premises include The relevant information can, again, be obtained
staff who provide assistance or care for vulnerable partly from the initial discussion with management,
persons, the number, roles and availability of staff but is primarily obtained by inspection of the
over the course of any 24 h period (particularly premises, so that the level of fire protection can
during the night) needs to be determined. be determined.
Information about previous fires is also of value,
e) The fifth step is to determine relevant information
particularly where the organization has multiple
about fire safety management (see 3.45).
sites with common operations. This information
This primarily involves discussion with
is described in Clause 12 as the “given” factors in
management, but might also involve examination
the FRA. Much of the relevant information can
of documentation, such as records of testing,
usually be obtained by interviewing a relevant
maintenance and training of staff (where present).
representative(s) of the management, prior to
carrying out a physical inspection of the premises. f) The sixth step is to make a (subjective) assessment
At that stage, it is important that relevant of the likely consequences to occupants in the event
information is obtained about the occupants of the of fire (see Figure 1). This assessment needs to take
premises, particularly those especially at risk in the account of the fire risk assessor’s opinion of the
event of fire. For example, in supported housing, it likelihood of various fire scenarios (see 3.51), the
would be necessary to obtain information about the extent of injury that could occur to occupants in
residents’ disabilities, and about the availability of these scenarios, and the number of people who are
staff to assist residents, if necessary, in the event of likely to be affected. This assessment is principally
fire. Other than in the case of small, simple premises, based on the fire risk assessor’s findings in steps four
the fire strategy for the building (if a documented and five, but takes account of information obtained
fire strategy exists) is likely to be of value to the in step one.
fire risk assessor. The term “fire strategy”, in this g) The seventh step is to make an assessment of the
context, includes the fire safety information that, fire risk and to decide if the fire risk is tolerable
for a modern building, is included in the package of (see Figure 1). The fire risk is assessed by combining
information that, in England and Wales, is handed the likelihood of fire and the consequences of fire
over to the dutyholder as part of compliance with (see Clause 18).
Regulation 38 of the Building Regulations 2010 h) The eighth step is to formulate an action plan
[22]. In Scotland, similar information is contained (see 3.2), if this is necessary to address shortcomings
within the Fire safety design summary [23] that is in fire precautions in order to reduce the fire
necessary for compliance with Regulation 41(bd) of risk. Even if fire risk is assessed as tolerable, there
the Building (Procedure) (Scotland) Regulations 2004 is often a need for minor improvements in fire
(as amended) [24]. precautions. (See Clause 19 for formulation of an
action plan.)

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PAS 79-2:2020

i) Thereafter, in the ninth step, a period of time 11.2 The FRA should be reviewed after a period of time
after which the FRA is to be reviewed needs to be defined in the FRA, or such earlier time as significant
determined (assuming that earlier review is not changes take place or there are other reasons to
necessitated by changes to the premises and that suspect that the FRA is no longer valid (see Clause 20).
there is no reason to suspect that the FRA is no
longer valid) (see Clause 20).

The nine steps set out above, while in a logical,


structured order, are not necessarily set out in the
chronological order in which the steps are carried
out on site. For example, some information relevant
to control of fire hazards, the determination of fire
protection measures and the management of fire safety
is normally most appropriately obtained in a single
meeting that is held prior to inspection of the premises.

11.1 In all FRAs carried out in accordance with this PAS,


the fire risk assessor should explicitly take the following
nine steps:
NOTE 1 Explicitly, in this context, means that, in the
documented FRA, it needs to be clear that each of the
nine steps has been taken by the fire risk assessor.
a) obtain information on the building, the fire strategy
for the building (where a documented fire strategy
exists), the premises and the people present, or
likely to be present, on the premises, and any recent
history of fires (see Clause 12);
NOTE 2 The relevant fire safety legislation requires
that consideration be given to the risk to people in
the immediate vicinity of the premises from fire, as
well as risk to people within the premises.
b) identify the fire hazards and means for their
elimination or control (see Clause 13);
c) assess the likelihood of fire, at least in subjective
terms (see Clause 14);
d) determine the fire protection measures currently in
the premises (see Clause 15);
e) obtain relevant information about fire safety
management (see Clause 16);
f) make an assessment of the likely consequences to
people in the event of fire, at least in subjective
terms (see Clause 17);
g) make an assessment of the fire risk (see Clause 18);
h) formulate and document an action plan, in which
recommended actions are prioritized (other than
in the case of an action plan comprising only
minor matters that can be actioned without delay)
(see Clause 19); and
i) define the date by which the FRA is to be reviewed
(see Clause 20).

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12 Information about the premises and their occupants

COMMENTARY ON CLAUSE 12 recorded in the FRA is a reasonably foreseeable


maximum, so that it forms a basis for any calculations
This clause sets out various “given” factors that have of required exit capacity, etc. (see Clause 15).
a major impact on fire risk. It is relevant to document In practice, in housing, it is very unusual for the capacity
information about these factors in the FRA. The manner of escape routes to be inadequate for the number of
in which the factors are to be taken into account in the persons who will use them.
FRA process is described.
Where staff are present and, within the building
Firstly, the number of floors below ground and the fire strategy, they have a role to play in assistance of
number of floors above ground need to be determined. vulnerable residents in the event of fire, information on
In assessing the fire risk, it needs to be borne in mind the ratio of staff to residents can be a relevant factor
that basements can present particular difficulties for to consider, though less so in buildings with a stay put
firefighting and, hence, rescue. Mitigating factors strategy (see 3.89).
would be, for example, low population within NOTE The relevant fire safety legislation requires that,
basement floors and the presence of fire protection other than in the case of certain very small businesses,
measures, such as automatic sprinkler protection, FRAs record any group of persons especially at risk.
automatic fire detection and means for removal
of smoke. The most important purpose of considering and
recording occupants especially at risk in the event of
Tall buildings, such as tower blocks, can result in fire, where appropriate, is to ensure that adequate
somewhat prolonged evacuation times for occupants. provisions are in place to protect such occupants from
External rescue by the fire and rescue service, though fire. Having recorded such occupants within the FRA,
only rarely necessary, is more difficult from floors above it needs to be clear within the documented significant
the height of normal fire and rescue service ladders findings that there are provisions to ensure the safety
and even more difficult in the case of very tall buildings of these occupants.
with floors beyond the reach of a turntable ladder or
hydraulic platform. The time for occupants to descend In supported housing, particular care needs to be
staircases in tall buildings can be significant. Again, taken to ensure that due account is taken of disabled
robust protection of staircases, smoke control and occupants, who are often especially at risk in the event
automatic sprinkler protection mitigate the risk. of fire in view of the possible need for assistance with
evacuation or special warning of fire. All forms of
The area of each floor can also be a relevant factor. disability need to be considered, including mobility
Complex escape routes might take longer to negotiate impairment, deafness, blindness, learning difficulties
than simple routes. The construction of the premises and mental illness. In sheltered and extra care housing,
also needs to be taken into account. This can have an more generic consideration of residents’ disabilities is
effect on fire development, particularly if combustible appropriate, and it is not usually practicable to consider
building construction is likely to be involved in the fire each resident individually. However, it needs to be
prior to evacuation of occupants. ensured that there are arrangements for identification
of people who are vulnerable in the event of fire, so
The general use to which the premises are put (the that, at least, the fire and rescue service can be made
occupancy) is also relevant. From a knowledge of aware of their presence on attendance at a fire.
the occupancy, conclusions can normally be drawn
regarding the nature and state of occupants, the In general needs housing, it is not expected to be
extent to which disabled people are resident in practicable for the FRA to identify disabled residents,
the building, etc. These are relevant factors in the particularly in the case of Type 1 and Type 2 FRAs.
assessment of fire risk. Even in the case of Type 3 and Type 4 FRAs, only a
sample of flats is visited, so only disabled residents
A further important consideration is the maximum living in the sample flats can be identified. Moreover,
number of occupants that can reasonably be expected in general needs housing, it is not expected that staff
at any one time. It is important that the number will be available to assist disabled residents in the

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event of fire; other means of mitigating the risk to NOTE 1 Where it is obvious that the external walls
such residents, such as enhanced smoke detection of the building have any form of cladding (i.e. are
within their dwellings, telecare enabled smoke alarms not of conventional masonry construction), or have
or automatic fire suppression might, however, be been overclad (e.g. with rainscreen cladding), or
appropriate, but this is more a matter for others, such new spandrel panels have been provided below
as landlords and social care organizations, than the fire windows, since the time of original construction, it
risk assessor. is appropriate to note this in the documented FRA.
It might be necessary to make a recommendation
In sheltered and extra care housing, it is much more in the action plan that external wall construction
feasible for the dutyholder to obtain, and maintain the and any cladding be subject to a fire risk appraisal
currency of, information on residents who would need and assessment by others to determine whether it
assistance with evacuation if they are required to do represents a fire hazard.
so by the fire and rescue service; it is normal practice NOTE 2 PAS 9980, which is in the course of
for this information to be made readily available to preparation at the time of publication of this
the fire and rescue service in the event of fire (e.g. by current PAS, will set out a code of practice for
keeping the information within a premises information fire risk appraisal and assessment of external wall
box, accessible only by the fire and rescue service, in the construction and cladding in blocks of flats.
entrance area of the premises, often close to the fire
NOTE 3 Certain modern methods of construction,
alarm control and indicating equipment).
such as timber frame construction, are worthy
of note (though often impossible to identify by
It is relevant to take account of any fire, however small,
visual inspection), as the risk arising from defects
that is known to have occurred within recent years.
in compartmentation can often be exacerbated
Factors to consider include the circumstances of the
by this form of construction. However, there is
fire, including the cause, and any remedial action taken
normally a need for reliance on information from
to prevent a reoccurrence. Information of this type
the dutyholder to establish that this form of
can be of use in identifying fire hazards that would
construction exists; it is the responsibility of the
not otherwise be obvious from an inspection of the
dutyholder to provide such information to the fire
premises. Where FRAs are carried out throughout the
risk assessor.
estate of one organization, review of the fire loss
experience throughout the estate can sometimes reveal d) any significant non-domestic areas of the premises,
significant trends or identify remedial action that might other than plant and similar rooms that would be
be appropriate throughout all premises to rectify a expected in the premises in question (e.g. communal
latent hazard. lounges, tenant halls and commercial premises);
e) approximate number of occupants;
Occurrence of vandalism, malicious fire-raising and f) in supported housing, the number of staff available
general antisocial behaviour in the area of the building, to assist residents with evacuation;
or within a block of flats, can sometimes be relevant
g) whether the premises will be occupied by a
in an FRA, as it might imply an increased likelihood of
significant number of persons other than residents
malicious ignition of, for example, waste and other
of dwelling units (or a significant number of persons
combustible materials in the immediate vicinity of
unfamiliar with the design and layout of the
the premises, such as to necessitate enhanced security
premises, other than residents’ visitors), and, if so,
measures or control over combustible materials external
the approximate number of such persons;
to the premises, as well as within the premises.
h) approximate gross floor area of the premises,
12.1 In carrying out the FRA, the fire risk assessor or a typical floor of the premises, or part of the
should take account of the following information: premises, that are the subject of the FRA;
a) brief details or brief description of the principal NOTE 4 It is not usually necessary to record more
dutyholder; than one measure of the size of a building (e.g. if
b) the height of the uppermost storey of the premises, the largest floor area of the premises or demise
or part of the premises, that is the subject of the under assessment is recorded, there is usually no
FRA, or the number of storeys above and below need to record the dimensions of any other floors).
ground; Where whole buildings are being assessed, it is
often sufficient to record the dimensions of the
c) brief details of construction, with information about
building footprint.
any aspects that make a significant contribution to
risk; i) the number of escape stairs and the floors that they
serve;

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j) the number of lifts serving the upper floors,


including specific reference to lifts intended for use
by the fire and rescue service;
k) occupants especially at risk (see 3.67) for whom the
premises are specifically designed (e.g. a proportion
of disabled residents that is significantly in excess of
that expected in the general population);
l) any fires that have occurred in recent years
(if known);
m) any further relevant information that has a bearing
on fire risk (other than the information described
in 5.3) or on the validity of the FRA;
n) information on any enforcement, alterations, or
prohibition notices that apply to the premises; and
NOTE 5 An alterations notice can be issued by an
enforcing authority under the relevant fire safety
legislation, requiring the enforcing authority to
be notified of proposals to carry out material
alterations to or a change in use of the premises.
o) any other matters that are considered relevant
by the fire risk assessor and that were taken into
account in the FRA [e.g. presence of staff, hours of
work or relevant working practices, tenure of flats
(if known) and arrangements for management];
these may be set out in a section recording other
relevant information that is not readily addressed
under other headings.
12.2 While it is not normally necessary to document
the manner in which every factor referred to in 12.1a)
to 12.1o) affects the FRA, there should normally be
explicit information within the assessment, where
relevant, regarding appropriate measures to protect
occupants who are especially at risk in the event of fire,
particularly in the case of supported housing with staff.

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PAS 79-2:2020

13 Identification of fire hazards and means for their


elimination or control

COMMENTARY ON CLAUSE 13 of all fires in blocks of flats in England). Two of these


fires were started deliberately, two were caused by
In this step of the FRA, the fire risk assessor identifies all electrical faults, while the cause of the fifth fire is
reasonably foreseeable and significant fire hazards and unknown.
examines the measures in place for their elimination or
control. By definition, this means considering potential It is inherent in the definition of fire hazard (see 3.31)
ignition sources (see 3.56), as well as situations and that fire hazards are not limited to ignition sources
unsafe acts that have the potential to result in a fire. per se. Various situations and unsafe acts can constitute
It is necessary, therefore, for the fire risk assessor fire hazards. For example, combustible storage or
to be aware of the common causes of fire in the rubbish does not, in itself, constitute a source of
type of premises under assessment, and to have an ignition. However, if, for example, the storage or
understanding of any effect that resident characteristics rubbish is positioned close to the windows of premises,
might have on the likelihood of fire and the nature of it might be ignited maliciously, or accidentally by
fires that might occur. There is also a need for the fire discarded cigarettes or matches (e.g. if a designated
risk assessor to have an understanding of the policies smoking area were located in close proximity), and
and procedures that contribute to prevention of fire. the resultant fire could then spread into the premises
At the conclusion of this step of the FRA, the fire risk via the windows. Such a situation would, therefore,
assessor is normally in a position to assess the likelihood constitute a fire hazard, as would bags of refuse placed
of fire (see Clause 14). in common parts of blocks of flats.

It is assumed that the fire risk assessor is already Poor housekeeping does not only result in potential
familiar with the common causes of fire and is for a fire to start; inappropriate quantities of poorly
either aware of recognized good practice in the located combustible materials can contribute to fire
elimination or control of fire hazards [i.e. is aware of development and, hence, the consequences of a fire
recognized fire prevention measures (see 3.35)], or as well as the likelihood of fire occurring. In particular,
has access to appropriate codes of practice. Normally, combustible materials in the common parts of a block
the documented FRA comprises a pro forma, which of flats, contrary to the policy on management of the
incorporates a prompt-list of fire hazards that need common parts, can result in a fire that undermines the
to be considered in the FRA. A suitable prompt-list of stay put evacuation strategy, which is founded on the
fire hazards typically found in housing premises, and premise that fire is unlikely to occur in the common
relevant codes of practice that give further guidance, parts, and that any such fire will be very limited in
are set out in Annex B. extent.

The list of fire hazards in the prompt-list in Annex B It is often appropriate to consider the means for
is not necessarily exhaustive, and other fire hazards control or elimination of fire hazards in two distinct
might need to be taken into account, particularly phases, which can be regarded as policy and practice
those specific to the type of housing, or the particular (see Figure 1). For example, in the case of a fire hazard
premises in question. For example, the presence of created by faulty electrical installations, one control
mobility scooters and electric vehicles in common parts measure would be a policy that the installation is
is a fire hazard, and a decision needs to be made as to subject to periodic inspection and testing.
whether, in the circumstances, the hazard is acceptable, The “practice” stage comes when the premises are
taking into account the needs of the user. On the inspected and observations can be made as to whether
other hand, fire hazards with negligible potential there is adherence to the policy (e.g. by examination
for harm need not be documented or given further of the last certificate of inspection and test if it is held
consideration. on the premises, or by checking the date of the last
NOTE The fire hazard of mobility scooters is not inspection and test recorded at the main electrical
always recognized because fires in mobility scooters intake). It might then be found that, for example, the
are uncommon (but might increase as mobility scooter inspection and test is overdue. It might also be helpful
usage increases). In 2015–2020, only five fires in blocks to the dutyholder if the date of the last inspection and
of flats in England involved mobility scooters (0.013% test is recorded in the FRA, regardless of whether or
not it is overdue.

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The relevant fire safety legislation requires that, in 13.2 Every FRA should include the following potential
carrying out the FRA, consideration be given to any sources of fire:
effects on the risk from fire of dangerous substances, a) malicious ignition;
such as flammable or highly flammable materials,
b) electrical faults;
oxidizing agents or materials that promote very rapid
fire development. In particular, such substances need to c) smoking;
be considered in relation to the effect that their storage d) cooking (if any is carried out other than in
or use has on the appropriate general fire precautions individual dwellings);
required by the relevant fire safety legislation, such e) inadequate control over the use of portable heaters;
as means of escape, fire warning systems (if any), fire
f) contractors’ activities and “hot work”;
extinguishing appliances and emergency procedures.
In practice, such substances are unlikely to be found in g) inadequate maintenance of heating installations; and
most housing premises. However, diesel fuel (as might h) lightning.
be found in a storage tank for a diesel generator in
a block of flats) is classified as a dangerous substance NOTE It is possible that there will be a need for
for the purpose of the relevant fire safety legislation, consideration of other fire hazards, including those
though the fire hazard is such that, in practice, few associated with storage and use of dangerous
special fire precautions are necessary. substances. However, it is uncommon to find these in
housing premises. Moreover, the relevant fire safety
Moreover, the use and storage of dangerous substances legislation excludes from the definition of general fire
is controlled under other legislation (the Dangerous precautions (in England and Wales), and the definition
Substances and Explosive Atmospheres Regulations or of fire safety measures (in Scotland and Northern
“DSEAR” [25]), which requires that a risk assessment Ireland), special, technical and organizational measures
is carried out. It is not expected that the fire risk required in relation to the use or storage of dangerous
assessor is competent to carry out this risk assessment, substances (as defined in the relevant fire safety
but, in carrying out the FRA, if materials classified legislation). Nevertheless, the effects of use or storage
as dangerous substances for the purpose of the on the general fire precautions (fire safety measures)
relevant fire safety legislation are noted, it needs to that are within the scope of the relevant fire safety
be confirmed that a DSEAR risk assessment has been legislation still need to be taken into account.
carried out. Equally, for small quantities of dangerous
substances, such as cans of thinners in a caretaker’s 13.3 Assessment of fire hazards should not be limited to
room, it is expected that the FRA will take into account those comprising specific sources of ignition. Situations
simple “housekeeping” issues, such as arrangements that could lead to a fire (and development of a fire),
for storage and arrangements for disposal of thinner- such as poor housekeeping, the presence of mobility
soaked rags. scooters and electric vehicles in common parts and
unsafe acts, should also be taken into account.
Electric vehicle charging points are provided within Any other hazards drawn to the attention of the
car parks in some developments. These can result in an fire risk assessor by the dutyholder, such as hoarding,
additional fire hazard, and in a risk to both members should also be taken into account.
of the public and firefighters, if they are the source of NOTE Inadequate security of access to a block of flats,
a fire or are involved in a fire. Accordingly, these and particularly in an area of known crime and antisocial
similar facilities, such as battery storage banks, need to behaviour, might also constitute a fire hazard.
be noted in the FRA.

13.1 The FRA should address means for elimination


or control of, at least, the common causes of fire, and
shortcomings in such measures should be addressed
within the action plan (see Clause 19).

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PAS 79-2:2020

14 Assessment of the likelihood of fire

COMMENTARY ON CLAUSE 14 If likelihood of fire is judged to be typical for premises


of the type in question, it is normally appropriate
Once all relevant fire hazards have been identified, and to ascribe to the premises the middle category of
measures for their control or elimination have been the predetermined categories of likelihood of fire.
determined, the fire risk assessor is in a position to Higher categories can then be used to indicate serious
make an assessment of the likelihood of fire. It would shortcomings in elimination or control of fire hazards
be possible, in theory, to associate a likelihood of fire (i.e. fire prevention), while lower categories can be
with each of the identified fire hazards. However, this used in cases where the likelihood of fire is abnormally
would make the FRA process unnecessarily complex low (e.g. because the extent of common parts within
and unduly lengthy. Usually, it is sufficient to assess the scope of the relevant fire safety legislation is
the overall likelihood of fire on the premises; this can minimal). Minor shortcomings in fire prevention
be regarded as the summation of likelihoods of fire measures need not be regarded as changing the
associated with each and every one of the fire hazards category ascribed to the premises, but need to be
identified. addressed in the action plan (see Clause 19).

The likelihood of fire need not, and usually cannot, 14.1 In the process of every FRA, an assessment should
be expressed in a meaningful numeric manner, such be made of the likelihood of fire.
as in terms of a statistical probability of fire. All that NOTE It is usual and acceptable for the likelihood of
is required is a subjective judgement that classifies fire to be expressed subjectively (e.g. “low”, “normal”
likelihood of fire into one of several predetermined or “high”).
categories. Since the assessment of these factors is
subjective, the use of numbers to express likelihood 14.2 If, in the FRA methodology adopted,
of fire does not confer any greater accuracy to the likelihood of fire is expressed in terms of one of
assessment of fire risk. several predetermined categories, the number of
predetermined categories should be an odd number,
The predetermined categories of likelihood of fire so that the middle category can be adopted for
may be described in the form of words, such as “low”, premises that are typical for premises of the type and
“medium” and “high”, or in the form of numbers occupancy in question. There should be at least three
(e.g. 1, 2 and 3), but there is a need for at least three predetermined categories.
categories. However, if likelihood is expressed in the
form of numbers, care is necessary to ensure that it
is not implied, for instance, that a likelihood of “2”
indicates that fire is twice as likely to occur compared
to a likelihood of “1”.

There is no upper limit to the number of categories


of likelihood that can be adopted in the FRA process.
However, if too many categories are adopted, the
distinctions between categories are meaningless.
Moreover, if the same FRA process is then applied to
numerous different buildings (e.g. within the estate
of a single organization), particularly by different fire
risk assessors, assessments of likelihood of fire are likely
to be inconsistent, and the benefits of comparing the
fire risk in different buildings (e.g. for the purpose of
prioritizing improvements on a building-by-building
basis) are then lost.

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15 Assessment of fire protection measures

COMMENTARY ON CLAUSE 15 suitably located for use by trained staff if any are
present (e.g. in a sheltered housing scheme manager’s
The following considerations are relevant to this clause. office, in plant rooms and in supported housing with a
staff presence); for example, fire extinguishers need not
a) General be provided in the common areas of blocks of flats or
In this step of the FRA, consideration is given to those sheltered housing.
physical measures incorporated within the premises
In some large premises, there is a need for access for,
that are intended to mitigate the consequences of fire
assistance to, or protection of, firefighters in the event
(and, hence, limit fire risk) in terms of harm to residents
of fire. Such measures can assist the firefighters in
and others in the event of fire. These measures are, by
effecting rescues if required.
definition, fire protection measures, and their effect is
to limit fire exposure (see 3.30). Particular care needs to
It follows, therefore, that the fire risk assessor needs
be taken where dangerous substances, as defined in the
to take account of, and assess the adequacy of, the fire
relevant fire safety legislation (e.g. oxygen cylinders)
protection measures recommended in 15.1.
are present; their presence might influence the need
for, and nature of, fire protection measures.
Adequacy of the engineering design, installation
and commissioning of fire protection systems and
When fire occurs, the first requirement is to warn those
products can often be certified by organizations that
people who need to be alerted, so that they can then
are themselves third-party certificated as competent
use suitably designed means of escape (see 3.64).
in their specialist field by an appropriate third-party
This might comprise all occupants of the building,
certification body. More generally, there is a need for
but, in blocks of flats, sheltered housing and extra care
all fire protection systems to be designed, installed,
housing, only the occupants of the flat of fire origin
commissioned and maintained by engineers competent
normally need to be alerted to the fire. (In the case of
in this specialist field.
sheltered and extra care housing, the remote
monitoring centre also needs to be alerted.) To enable
Fire development and spread can be passively
people to use means of escape safely and efficiently,
limited by fire protection measures (see 3.37),
there is often a need for appropriate signs and for
such as fire‑resisting walls and floors (over and
emergency escape lighting (see 3.19). However, in
above any required to protect means of escape),
simple straightforward housing premises, care is
which can be used to subdivide the premises into
necessary to ensure that unnecessary signage does not
a number of separate fire compartments [e.g. to
create the environment of an institutional building.
satisfy the requirements of building regulations for
For example, in supported housing that takes the form
compartmentation (see 3.13)]. This is particularly
of a traditional dwelling, many HMOs, small sheltered
important in blocks of flats, sheltered housing and
housing schemes and blocks of flats with a single
extra care housing with a stay put strategy
stairway, fire exit signs are commonly unnecessary.
(see 3.89); in these blocks, each flat is a fire
compartment bounded by fire-resisting walls and
Harm to occupants might also be mitigated, and
floors (other than walls forming part of the external
safe escape facilitated, by appropriate measures to
envelope of the building). It is normally relevant,
control or extinguish the fire by use of portable fire
therefore, for the fire risk assessor to take account
extinguishers or by activation of an automatic fire
of such fire‑resisting construction and to address
suppression system, such as an automatic sprinkler
its maintenance [e.g the adequacy of fire stopping
system. However, again, in housing premises, residents,
(see 3.52)], often by inspecting sample areas of
who are unlikely to have been trained in the use of
construction. The spread of fire can also be actively
fire extinguishers, are not expected to attempt to
limited by automatic fire suppression systems.
tackle a fire; they might put themselves and any family
members at risk in so doing. It is for this reason that
On the other hand, fire development can be assisted
fire extinguishers are not normally provided in the
by, for example, flammable linings on walls or ceilings,
common parts of housing premises, other than those
or by readily flammable furniture and furnishings, and

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by the accumulation of combustible material, including In Northern Ireland, the relevant fire safety legislation
waste material. The fire risk assessor needs to take into does not require an FRA to be carried out for the
account the presence and location of these features common parts of blocks of flats, sheltered housing or
and, sometimes, their physical state. For example, extra care housing. Guidance on fire safety in HMOs
damage to upholstered furniture (e.g. in a communal and supported housing has been produced by the
lounge within sheltered housing) can result in exposure Northern Ireland Fire & Rescue Service in conjunction
of foam fillings, which might be easily ignited and with the Housing Executive [26].
result in rapid development of fire.
b) Fire detection and warning
Since the earliest effect of fire on occupants is often The arrangements for any necessary measures for
loss of visibility on escape routes as a result of smoke, detection of fire, and the means for then warning those
there is also a need to take account of measures to limit occupants who need to be alerted to the fire, ought to
spread or build-up of smoke. These can range from fire be taken into account. Fire can be detected by people
doors (see 3.27) to active smoke control systems, such or by automatic fire detectors. If people are present in
as those designed to ventilate or extract smoke, or to the area of fire origin, they normally detect fire before
maintain a positive pressure within escape routes to it is detected automatically by, for example, smoke or
prevent the ingress of smoke. heat detectors.

In the sections of commentary that follow, the key Fire detection and fire alarm systems are not
fire protection measures that affect the consequences appropriate in the common parts of general needs
of fire are discussed separately. The measures are blocks of flats with a stay put strategy (though fire
not, however, independent. In assessing the likely detection might be necessary as part of smoke control
consequences of fire (see Clause 17), a judgement arrangements or in certain ancillary areas, such as car
needs to be made regarding the overall effect of each parks). In carrying out the FRA in such buildings, care
of the fire protection measures discussed below in needs to be taken to ensure that an appropriate stay
combination, and of a number of the management put strategy is not contradicted by inappropriate fire
issues discussed in Clause 16, on the RSET (see 3.80) or alarm systems; to do so can place residents at risk and
on the ASET (see 3.6). result in liability on the part of the fire risk assessor
for consequent injuries, particularly if the fire risk
For England and Wales, guidance on fire protection assessor makes recommendations for an inappropriate
measures for purpose-built blocks of flats is published or unnecessary system. However, fire detection and fire
in a Local Government Association publication [1], alarm systems are normally necessary in:
while guidance on fire protection measures for 1) the communal areas of many sheltered housing
HMOs is given in a publication originally produced by schemes, unless there are no communal facilities
Local Authority Coordinators of Regulatory Services and the common parts are reasonably devoid of
(LACoRS) [7] and in more general guidance produced combustible furniture, etc.;
by the then Department of Communities and Local 2) HMOs;
Government on measures required by the Fire Safety
3) some houses converted into blocks of flats, in which
Order [5] in premises in which people sleep. For
the fire safety design or constructional features
specialized housing in England and Wales, guidance
cannot support a stay put strategy;
on fire protection measures is given in the National
Fire Chiefs Council publication Fire safety in specialised 4) supported housing, unless it is purpose-built and
housing [3]. designed on the basis of a block of flats with a stay
put strategy; or
In Scotland, the relevant fire safety legislation does 5) some old purpose-built blocks of flats that have
not require an FRA to be carried out for the common inadequate compartmentation (or possibly
parts of blocks of flats, sheltered housing or extra care inadequate design of means of escape) to support a
housing. However, guidance on fire safety in high-rise stay put strategy.
blocks of flats (over 18 m in height), and on carrying NOTE 1 Advice on fire detection and fire alarm systems
out an FRA for these buildings, is published by Scottish for these buildings is given in the guidance to which
Government [2]. Scottish Government also publish item a) of the Commentary on Clause 15 refers.
guidance on fire safety in HMOs [12] and on fire safety More detailed recommendations on fire detection and
in specialized housing [3]. In Scotland and Northern fire alarm systems for all types of domestic premises,
Ireland, FRAs are required by the Fire (Scotland) Act including all those within the scope of this PAS, are
2005 [8] and the Fire and Rescue Services (Northern given in BS 5839-6.
Ireland) Order 2006 [13] in licensed HMOs and in
supported housing.

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Fire detection is necessary within all dwellings, detection and fire alarm system in the common areas
including general needs flats, and flats in sheltered is normally unnecessary and inappropriate). Domestic
and extra care housing. In a Type 3 or Type 4 FRA for smoke alarms are suitable for small HMOs, but, for
purpose-built blocks of flats and specialized housing, large HMOs, fire detection alarm equipment of the
the adequacy of this fire detection (which, particularly type specified in the BS EN 54 series is necessary.
in general needs blocks of flats, normally comprises
domestic smoke and heat alarms) needs to be checked. Most premises in which automatic fire detection is
required within common parts (e.g.an HMO) also
In England and Wales, for new dwellings, compliance need manual call points. In small properties, it might
with Approved Document B [21] requires only smoke not be necessary for these to be installed on every
detection in the circulation areas of a dwelling. level. It is also unnecessary to install manual call
The equivalent guidance in Scotland [27] and Northern points in HMOs in which automatic fire detection
Ireland [28] specifies additional fire detectors in the comprises the provision of Grade D fire detection
principal habitable room and kitchen. and fire alarm systems. The judgement of the fire risk
assessor is necessary in this respect, having regard
For existing private rented dwellings in England, to the appropriate guidance for the type and size of
legislation requires that a smoke alarm is provided property in question. In some premises, the provision of
within the circulation space on each level. Guidance manual call points might be undesirable because of the
on this requirement is published by MHCLG [29]. likelihood of malicious operation.
For existing private rented dwellings in Scotland, in
addition to these smoke alarms, a smoke alarm needs If it has been identified in an FRA that Deaf or hard
to be provided in the principal habitable room, in of hearing occupants are, or are likely to be, present
conjunction with a heat alarm in the kitchen. in any of the dwellings (e.g. in supported housing),
Guidance on the requirements for private rented consideration needs to be given to means for warning
dwellings in Scotland is published by Scottish them in the event of fire. This might simply comprise
Government [30]. This standard of protection will be suitable assistance from the occupants’ family, but
required in all existing dwellings in Scotland during could necessitate flashing beacons or even special
the life of this PAS. means of warning, such as vibrating pagers or digital
NOTE 2 Guidance on fire detection within dwellings is messaging systems.
given in BS 5839-6.
Although a facility can be provided for fire alarm
In specialized housing, there is a need for a higher signals to be transmitted automatically to an alarm
standard of coverage by automatic fire detection within receiving centre (see 3.3) from where the fire and
flats than is necessary in flats within general needs rescue service is summoned, in most housing premises,
housing. Guidance on fire detection for specialized this is not normally necessary for the purpose of life
housing is given in BS 5839-6. Guidance, for England safety. However, in sheltered and extra care housing,
and Wales, is also given in the National Fire Chiefs the early summoning of the fire and rescue service is
Council guide, Fire safety in specialised housing [3]; critical, and so signals from fire detection in dwellings
in Scotland, equivalent guidance is published need to be relayed to an alarm receiving centre that
by Scottish Government [4]. can establish two-way speech communication with a
flat of fire origin, normally via a social alarm system.
Older fire detection and fire alarm systems might Automatic transmission of fire alarm signals to an alarm
not conform in full to current standards, particularly receiving centre might also be necessary in certain
in respect of certain aspects of engineering design. supported housing in which staff levels at certain times
In many cases, this is perfectly acceptable, but might be low.
it is expected that new systems and new work
associated with the modification of existing systems, Normally, in an FRA, the functionality of a fire
recommended in the action plan, will conform to detection and fire alarm system is checked [i.e. by
current standards. a simple visual check of the control and indicating
equipment (CIE) display], but it does not involve any
NOTE 3 Guidance on types of fire detectors, their
detailed engineering evaluation of the system. It needs,
application and limitation of false alarms is given in
however, to be confirmed that the fire detection and
BS 5839-1.
fire alarm system is subject to routine testing and
NOTE 4 Domestic smoke alarms are unsuitable for maintenance, so that faults and major shortcomings
installation in the common parts of purpose-built blocks are identified by this means (see Clause 16). Moreover,
of flats (though, in any case, the provision of a fire it is normally appropriate for the fire risk assessor to

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PAS 79-2:2020

consider whether the fire alarm signal is likely to be distance of travel, turn their back on any fire and
audible in all relevant areas of the premises, based on move towards a place of relative safety (see 3.73) and
a visual inspection of the locations of sounders, even ultimately a final exit (see 3.25) along smoke-free
though shortcomings are normally identified by routine escape routes.
testing. The FRA might then recommend, within the
action plan, that an engineering evaluation, including Five critical factors in the assessment of means of
measurement of sound pressure levels in “suspect” escape are therefore:
areas, be carried out. Where visual alarms are necessary, 1) the maximum distance occupants need to travel to
some consideration of their visibility is appropriate. reach a place of relative or ultimate safety (see 3.73
and 3.74 respectively), such as an exit to a protected
c) Means of escape stairway (see 3.77), or to a final exit (see 3.25);
In considering the likely consequences of fire, the fire 2) the avoidance of long dead ends (see 3.16) in which
risk assessor needs to determine the likely effects of escape is possible in only one direction;
fire on escape routes (see 3.21) during evacuation of 3) the number, distribution and, occasionally, widths of
the building or evacuation of a flat(s) affected by a fire. storey exits and final exits;
This requires a thorough evaluation of means of escape.
4) the means of protecting escape routes from ingress
or build-up of smoke that prevent occupants’
If the means of escape conform to the requirements of
escape; and
modern building regulations, it is unlikely that a need
for major improvements will be identified in the FRA. 5) the ability of occupants to use the escape routes.
Suitable benchmark standards for means of escape
include guidance that supports legislative requirements In some types of housing, it can normally be expected
for fire safety in existing buildings. that disabled residents, or residents who are otherwise
vulnerable in the event of fire, are likely to be present
However, means of escape are just one of the fire on the premises. Examples are sheltered housing, extra
protection measures that affect the consequences of care housing and supported housing. In those buildings
fire and, hence, the fire risk. Therefore, a departure with a stay put strategy, the level of compartmentation
from one or more recommendations given in the is favourable to these residents, as, in the event of
relevant codes of practice regarding means of escape fire, unless the fire occurs within their own dwelling,
might be acceptable when all other fire precautions they can normally remain within the safety of their
are taken into account. Such other fire precautions own dwelling; there is, therefore, no expectation that
include early warning of fire, rapid response to the staff will be present to assist with evacuation. If a fire
warning by occupants and measures to increase the occurs within their own dwelling, rescue by the fire and
ASET (see 3.6). Departures from traditionally quoted rescue service might be necessary. Advice on evacuation
travel distances could also have arisen when the can be found in the guidance to which item a) of the
premises were designed if the designer used the Commentary on Clause 15 refers.
approach given in BS 9991, which, for example, permits
extended travel distance within the common parts of Many supported housing premises are not constructed
blocks of flats if the flats themselves are sprinklered. in this manner (simply comprising various forms
Where the premises are complex and departures from of typical single-family dwelling houses converted
conventional design principles are significant, there for use as supported housing); in these properties,
might have been a need for a fire engineering solution consideration needs to be given to any need for
of the type to which BS 7974 is relevant; the fire risk assistance with the simultaneous evacuation of all
assessor will need to be given information regarding residents, which cannot rely on the assistance of the
such a solution, as it is difficult to “reverse engineer” fire and rescue service. (A system of phased evacuation
the principles of, and assumptions made within, a fire is unlikely to be acceptable.) As in any premises with
engineering solution simply from an inspection of the simultaneous evacuation, there is a need for the FRA
premises. to consider the evacuation of disabled people and
how this can, if necessary, be facilitated (i.e. by staff).
The first effect of a fire on the safety of occupants is In some supported housing, an automatic fire
often the presence of smoke in escape routes. suppression system might be necessary to support
This results in loss of, or reduction in, visibility. evacuation. Again, advice can be found in the
Thus, in general, adequate means of escape are guidance to which item a) of the Commentary on
provided if people can immediately, or within a short Clause 15 refers.

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In general needs blocks of flats, the presence of forcible entry to a flat, from which the disabled
disabled residents is likely to reflect the extent of occupant is temporarily absent, potentially placing
disability in the general population, although this firefighters at risk or directing their resources away
might be higher in social housing. However, it is not from rescue of residents who are present.
normally practicable for a freeholder or landlord to
make special arrangements (e.g. specially equipped, This is not to suggest that measures to enhance the
designated refuges) for evacuation of these residents safety of those disabled residents who make their
by staff in the building in the event of fire. Moreover, disability known to the housing provider, cannot be
consideration of evacuation of residents from their made. In a general needs block with a stay put strategy,
own flats is outside the normal scope of a Type 1 FRA, if the fire is in a disabled person’s flat, the situation
though it can be relevant in a Type 3 or Type 4 FRA; is little different from a disabled person living alone
for example, in these FRAs, consideration can be given in a house. If the fire is in another flat in the block, a
to additional fire protection measures and possible disabled resident ought to be safe to remain within
provision of a social alarm system to summon assistance their own flat, unless the fire and rescue service
(normally from the fire and rescue service) in the determine that there is a need for evacuation of that
event of fire. Arrangements need to be made for the flat. In both cases, there might be a need for rescue
provision of contact numbers for persons with whom by the fire and rescue service. The safety of a disabled
disabled people can discuss and plan evacuation in the resident can be enhanced by extensive provision of
event of fire. smoke alarms within their flat in conjunction with
telecare monitoring of the smoke alarms, enabling
In general needs blocks of flats, it has, traditionally, two-way speech communications between the resident
been accepted that it is, normally, wholly unrealistic and a social alarm receiving centre. Additional
to expect the housing provider to prepare personal protection of the resident against a fire in their own
emergency evacuation plans (PEEPs) for all residents flat can be provided by an automatic fire suppression
who might need assistance with evacuation in the system. However, these matters are outside the scope
event that it becomes necessary (i.e. on the instructions of the Fire Safety Order [5] and are, hence, outside the
of the fire and rescue service). However, in response to scope of a Type 1 FRA.
the recommendations of Phase 1 of the Public Inquiry
into the Grenfell Tower fire, the Government is, at the In sheltered and extra care housing, there is normally
time of publication of this PAS, proposing to make greater engagement between residents and staff of the
regulations for England and Wales that necessitate housing provider or care provider. In these premises, it
collation of information regarding disabled people is normally possible to maintain, and update, relevant
who cannot self-evacuate in the event of fire, so that records in relation to residents’ disabilities, including
it is available to the fire and rescue service. Fire risk PEEPs. The PEEPs are normally located within a secure
assessors need to ensure that they monitor the progress premises information box, to which the fire and rescue
of any new legislation in this respect, which will be service have access (e.g. by means of a key that is
taken into account in the next revision of this PAS. protected from copying through patent and/or three-
dimensional trademark and that is carried on fire and
In the meantime, it is relevant to note that such rescue service appliances, or by use of a code known
arrangements are not without certain major challenges. to the fire and rescue service, or by remote electronic
Apart from the difficulty in collating such information, release). In sheltered and extra care housing, the FRA
it would be necessary for the information to be needs to verify that, where appropriate, relevant
updated regularly, and, in general needs flats, it is not up-to-date information, which can include those flats
practicable to take account of the daily movements of in which residents use oxygen cylinders, is held in a
residents. Inaccurate information could potentially be premises information box.
more harmful than no information. In general needs
blocks of flats, no staff are normally available to assist The subject of design of, and arrangements for,
with evacuation, so PEEPs would, effectively, take the means of escape is outside of the scope of this PAS.
form of rescue plans for use by the fire and rescue It is assumed that the fire risk assessor has sufficient
service. Unless there were arrangements to monitor the knowledge of the principles of means of escape
movement of disabled residents on a day-by-day basis to assess the adequacy of the means of escape in
(which is technologically possible), there is potential the premises in question. Moreover, the number of
for such rescue plans to lead firefighters to consider component factors that need to be taken into account

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is greater than in the case of other fire protection produced by Scottish Government for high-rise blocks
measures. Accordingly, Annex C sets out the key factors of flats [2].
to consider when assessing means of escape. However, NOTE 5 Attention is drawn to the guidance on existing
in the case of specialized housing, care needs to be flat entrance doors in England and Wales, set out in
taken to ensure that any special considerations that are Annex A of the MHCLG Advice for building owners of
appropriate are properly addressed. multi-storey, multi-occupied residential buildings [31]
[see also item g) of the Commentary on Clause 15].
In all forms of housing, one of the most important This guidance refers the building owner to the LGA
issues to consider in an FRA is the fire performance of guide, noting that the LGA guidance is supported by
doors that separate residents’ accommodation from the National Fire Chiefs Council. The MHCLG advice is
communal escape routes. It is essential that these doors that building owners aim to replace existing timber
are self-closing and that they afford adequate fire flat entrance doorsets if they suspect that the doorsets
resistance. This is particularly important in blocks of do not meet the fire or smoke resistance performance
general needs flats, sheltered housing and extra care contained in the LGA guide, using risk assessment
housing, but might be of equal importance in some to determine the urgency for such replacement.
supported housing. For flats, sheltered housing and It is relevant to note that, in many circumstances, the
extra care housing, it is normally impracticable, in the LGA guide recommends that “notional FD 30 doors”,
course of an FRA, to gain access to all flats to check namely door assemblies that satisfied the current
the flat entrance doors; the dutyholder needs to have specification, or fire resistance test, for 30 min at the
arrangements in place for periodic, routine checks to time of construction of a block of flats or manufacture
confirm that flat entrance doors remain self-closing and of the door, remain acceptable; in older blocks, these
free from damage (to an extent that would impair their doors are not fitted with intumescent strips and/or
fire resistance). Common custom and practice is for fire smoke seals.
risk assessors to endeavour to check around 10% of flat
NOTE 6 At the time of publication of this PAS,
entrance doors (with a minimum of two doors), though
in England and Wales, there is a proposal by the
this is not always possible.
government to clarify, by means of a new Fire Safety
Bill, that flat entrance doors in blocks of flats fall within
It is also important that fire doors in protected
the scope of the Fire Safety Order [5].
lobbies and stairways are self-closing and adequately
fire‑resisting. Normally, there is no impediment to
In some specialized housing, there is often a need
access in respect of these doors, all of which, therefore,
for fire doors to be held in the open position, but
need to be checked by the fire risk assessor. It is also
to self‑close automatically on operation of the fire
important that these doors are subject to routine,
alarm system. Similarly, in both blocks of flats and
periodic inspection by the dutyholder.
specialized housing, there is often a perceived need
for electronic locking of final exit doors, which are
A common issue to arise in an FRA is the fire resistance
unlocked automatically on operation of any fire alarm
of all of the above doors (see also Clause 9). Older
system that is present (e.g. in many sheltered housing
doors are not fitted with intumescent strips (and so
premises). The reliability of the arrangements for
do not achieve 30 min fire resistance), nor are they
automatic operation of door release mechanisms and
fitted with smoke seals (see also Clause 9). Whether
electronic locks in the event of fire needs to be taken
this materially impacts on fire risk is a matter
into account in the FRA; for example, it needs to be
for judgement by the fire risk assessor, taking all
confirmed that, unless there is a mechanical means
relevant factors into account. It is inappropriate to
of releasing the lock (e.g. a lever handle) to facilitate
make generic recommendations for upgrading, or
escape, electronic locks release on failure of the power
replacement, of doors to satisfy current standards,
supply to them. Electronic locks, particularly those of
without proper consideration of risk and cost benefit.
an electromechanical nature, can potentially introduce
In many cases, doors that satisfied requirements for fire
an additional risk, and the potentially conflicting
resistance at the time the building was constructed,
requirements of security and fire safety need to be
or the doors were manufactured, will continue to
carefully balanced; unless the access control system
afford adequate fire resistance to protect escape
incorporates suitable design features, electronic locks
routes. Recommendations for generic upgrading or
might also delay access for the fire and rescue service.
replacement of doors without proper justification of
Recommendations on the interface between a fire
the risk associated with existing doors ought to be
detection and fire alarm system and these types of door
challenged by dutyholders. Further guidance in relation
release mechanism are given in BS 7273-4.
to fire doors in purpose-built blocks of flats can be
found in the LGA guide [1] and equivalent guidance

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d) Signs and notices NOTE 9 In buildings with complex escape routes, an


In housing premises, there is commonly no need to escape plan might be displayed to indicate escape
provide fire exit signs to direct people towards means routes. Design principles for escape and evacuation
of escape, particularly where there is only a single plan signs are given in BS ISO 23601.
stairway. To provide these unnecessarily simply creates
an undesirable ambience of an institutional building. e) Emergency escape lighting
However, in large or complex buildings, it might be If escape routes require artificial illumination, there is a
necessary to indicate alternative means of escape that need to determine whether emergency escape lighting
are not in use as the normal means of access and egress. is necessary. Normally, emergency escape lighting is
It is, therefore, important, in the FRA, to determine necessary on all escape routes in housing premises,
whether fire escape signage is necessary. except, for example, a small, two-storey block of flats
NOTE 7 In the cases of premises that are workplaces, with good borrowed lighting or a small supported
it is a requirement of the Health and Safety (Safety housing bungalow with automatic plug-in night lights.
Signs and Signals) Regulations 1996 [32] that these Normally, this comprises non-maintained emergency
signs incorporate the appropriate pictogram. lighting (3.66), but maintained emergency lighting
Recommendations on escape route signs are given in (3.60) is equally acceptable.
BS 5499-4. NOTE 10 Attention is drawn to guidance documents
that support building regulations (e.g. in England and
In the course of the FRA, there is also a need to Wales, Approved Document B [21]) for guidance on the
determine whether other forms of fire safety signs and need for emergency escape lighting in new buildings.
notices are necessary, and whether those provided are
adequate. Examples include: If a judgement is made that emergency escape lighting
1) other safe condition signs (see 3.81) (e.g. indicating is not necessary, it is appropriate for this to be justified
use of escape hardware); in the documented FRA (see Clause 10).
2) signs on fire doors, indicating the need for the
doors to be kept shut, kept locked shut or kept clear Normally, the FRA does not involve any detailed
(in the case of automatically closing fire doors), as engineering evaluation of an emergency escape
appropriate; lighting system. However, it is important to confirm
that the system is subject to routine testing and
3) other mandatory signs (see 3.61), such as those
maintenance, so that faults and major shortcomings are
indicating the need to keep a fire exit clear;
identified by this means (see Clause 16).
4) fire equipment signs (see 3.29), primarily where, for
example, fire extinguishers or fire alarm call points Moreover, it is normally appropriate for the fire risk
are hidden from direct view; assessor to determine whether the extent of an existing
5) “no smoking” signs; system is sufficient, based on a visual inspection of the
6) fire procedure/fire action notices; areas of coverage and the provision of luminaires, and
whether the duration for which emergency escape
7) storey identification signs and dwelling indicator
lighting can be provided is adequate; this is normally
signs in blocks of flats; and
3 h. The FRA might, nevertheless, recommend within
8) warning signs (e.g. photovoltaic cells, electric the action plan that an engineering evaluation be
vehicle charging points). carried out, including verification of the adequacy of
NOTE 8 Attention is drawn to the Domestic Technical levels of illuminance. It is also normally appropriate
Handbook [27] that supports building regulations in to confirm that there are suitable facilities for routine
Scotland, which, since October 2018, has specified that, testing of the installation.
to assist the fire and rescue service, storey identification
signs and dwelling indicator signs be provided in blocks In some cases, an existing emergency escape
of flats with a storey height over 18 m. In England, the lighting system does not conform in full to current
same measure has applied to new blocks of flats over recommendations (e.g. in respect of illuminance levels).
11 m in height from November 2020. This might be acceptable, but it is appropriate for new
systems, and new work associated with upgrading of
Guidance on the selection and use of safety signs existing systems, recommended in the action plan, to
(including various fire safety signs) and fire safety conform to the current recommendations.
notices (but excluding escape route signing) is given NOTE 11 Attention is drawn to the recommendations in
in BS 5499-10. Registered safety signs are given in BS 5266-1 and to the requirements of BS EN 1838 and
BS EN ISO 7010. BS EN 50172.

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f) Manual firefighting equipment As many areas where service penetrations could lead
It is not normally appropriate for housing premises to to breaches of compartmentation might be hidden,
be provided with means for residents to extinguish a such sampling might need to include areas above
fire, particularly within common parts of blocks of flats, false ceilings where many services often run. More
sheltered housing or extra care housing. Extinguishers generally, since any structural barrier will resist the
are normally provided only in areas such as plant passage of smoke or fire for at least some time, obvious
rooms, communal kitchens (in which fire blankets shortcomings in fire stopping of service penetrations
are also appropriate) and lounges (e.g. in sheltered need to be addressed in the action plan (see Clause 19).
housing), workplaces (such as offices) and suitable Clause 21 provides guidance and recommendations
locations for staff to use in supported housing; such on the intrusive inspection and opening up that are
locations might be within the hallway of a supported appropriate in Type 3 and Type 4 FRAs.
housing property. If, very unusually, a fire risk assessor
were to decide that there was a need for portable fire Roof voids are a potential area through which fire can
extinguishers in areas other than these examples, there spread if a fire either starts in the roof void or spreads
would need to be full and clear justification for this into it from a flat below (e.g. directly, via ventilation
conclusion in the FRA. ductwork or via the eaves). In old blocks of flats, it
is not uncommon to find that compartment walls
If appropriate fire extinguishers are necessary, between flats do not extend through the roof void, as
consideration might be given to the use of would now be necessary for compliance with building
multi-purpose extinguishers, which can be used on regulations, thereby enabling unlimited fire spread
more than one class of fire (see 3.7 to 3.11). However, across multiple flats. However, issues can also arise in
where the risk is predominantly associated with the design and maintenance of low-rise pitched roof
electrical equipment, carbon dioxide extinguishers are buildings, such as are commonly found in modern
likely to be the most appropriate type. sheltered housing. Fire spread within roof voids over a
modern sheltered scheme has led to at least one fatal
Hose reels are not normally appropriate for housing fire, in which a resident died in her own flat, two flats
premises, and dry powder fire extinguishers are not away from the flat of fire origin. For these reasons, it
recommended for use indoors. is important that the fire risk assessor endeavours to
include roof voids in even a Type 1 FRA, albeit that
g) Structural and similar passive measures to limit fire an element of sampling is acceptable. Access to roof
spread and development voids can be difficult, and, if access is not considered
practicable, this needs to be made clear in the
In the course of the FRA, consideration needs to be
documented FRA.
given to structural and similar passive measures that
are intended to limit the spread and development of It cannot be assumed that simply because a building
fire within the premises (in addition to consideration has been recently constructed, and that a completion/
already given to similar measures that are specifically final certificate has been issued by a building control
intended to protect means of escape). In some simple body, there is a reduced need for consideration of
premises in which compartmentation (see 3.13) was not compartmentation and fire stopping. In the few
necessary at the time of construction for compliance years prior to publication of the current version of
with the relevant building regulations, there might be PAS 79, numerous cases of poor construction work
no such measures (e.g. a bungalow used for supported in newly, or recently, constructed buildings have
housing). come to light, including inadequate fire stopping of
junctions between fire-resisting barriers, and of service
However, where compartment walls or floors are
penetrations, etc., and incomplete construction within
provided, some consideration needs to be given to
risers and above fire doors. Some cases have been
the likely integrity of these. Usually, in the course of
so serious that it has been necessary for enforcing
the FRA, a detailed examination of the construction of
authorities to consider prohibiting the use of the
the premises is not practicable. For example, a Type 1
building under the Fire Safety Order [5].
FRA would not normally involve opening up work,
such as cutting holes in, or removal, of walls, ceilings, Consideration of compartmentation in the FRA is
partitions, etc. Normally, there can only be visual particularly important in all premises in which, in the
inspection of a sample of reasonably accessible areas event of fire, there is no simultaneous evacuation, such
[e.g. to check visually for any obvious inadequacies as blocks of flats with a stay put strategy (see 3.89).
in fire stopping (see 3.52)]. Sometimes transmission In these premises, there is reliance on
of noise or cooking odours between flats can be an compartmentation (e.g. of each flat) for protection
indication of a weakness in compartmentation.

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of occupants who remain within the building in the However, particularly where the age of the premises,
event of a fire within one dwelling. In all of these or the likely extent of modifications to the premises,
buildings, it is of value for the fire risk assessor to might suggest that ductwork could act as a route for
ensure that the dutyholder is aware of the importance spread of smoke into, or within, escape routes, some
of compartmentation. investigation might be needed, or it might be necessary
to recommend further investigation in the action
Traditionally, it has been regarded as good practice to plan, if the siting of visible air extract or supply points
enclose areas of high fire hazard and plant rooms in suggests that dampers are essential.
construction of appropriate fire resistance (see 3.38).
The need for this is, therefore, normally considered in It was traditionally accepted that the external walls of
the FRA. the building were outside the scope of the relevant
fire safety legislation (even if the common parts fall
In new building work, the flammability of wall and within the scope). However, a fire hazard can result
ceiling linings is controlled under building regulations. from inappropriate construction of external walls and
If the linings continue to conform to the original the combustibility of any cladding, including rainscreen
requirements in this respect, they are likely to be cladding, attached to the external walls of the building.
satisfactory. However, consideration needs to be given This can cause an external fire (whether started
to the issue of linings, as unsatisfactory linings can externally by, for example, a burning car or refuse, or
promote the spread and development of fire. by flames from an internal fire emanating from, for
In unusual circumstances, it might be appropriate to example, windows) to bypass compartment floors and
consider whether multiple layers of paint in common walls, so undermining the stay put strategy in a block
parts can affect the potential for spread of flame of flats.
over walls, although this is normally very difficult to
determine. In some premises, such as sheltered housing, In 2017, the fire at Grenfell Tower (a high-rise block of
the flammability of any furniture and furnishings that is flats in London), in which 72 deaths occurred, as well
permitted within common parts needs to be taken into as some other previous, overseas fires, brought to the
account. fore the hazard of rapid vertical (and, to some extent,
horizontal) fire spread that can occur as a result of
Ventilation systems can provide a path for spread of fire highly combustible external cladding. For the purpose
and smoke. Particularly in older blocks of flats, of the consideration of this matter in an FRA, spandrel
bathroom or kitchen extract systems from flats panels need to be regarded as equivalent to cladding,
sometimes share a common extract duct, sometimes as, if their fire performance is inadequate, they too
with no effective measures to prevent spread of fire or have been shown in fires to promote rapid vertical fire
smoke between flats; this could undermine a stay put spread. In consequence of the fire at Grenfell Tower, in
strategy. In an FRA, it is not normally possible to carry England and Wales, by amendment of the Fire Safety
out an examination of the extract arrangement to Order [5], the external walls of a building that contains
determine whether suitable measures, such as shunt two or more domestic premises will expressly fall within
ducts (or dampers; see 3.15.1 to 3.15.3), were taken at the scope of the Order.
the time of construction to prevent this. However,
endeavours need to be made to determine whether There is a requirement under building regulations
common extract systems are present, so that, if throughout the UK that external wall construction
necessary, further investigation can be recommended. be such that spread of fire over external walls is
Guidance is given in the Local Government Association adequately restricted or inhibited. However, for new
publication Fire safety in purpose-built blocks of flats [1]. buildings, material alterations of existing buildings
and material change of use of existing buildings, more
More generally, in an FRA, it can be difficult to specific requirements of the building regulations on this
determine whether the measures incorporated matter, as well as the associated current government
within the design of ventilation and air conditioning guidance on compliance, differ between Scotland,
systems are adequate. Access to false ceilings within Northern Ireland, England and Wales. Accordingly, it
which ductwork runs can be difficult; frequently is essential that the fire risk assessor is familiar with
there is difficulty in determining whether dampers current regulations and guidance for new building
are fitted at appropriate locations. In general, the work as a starting point in consideration of the matter
appropriate measures are likely to have been required (see Figure 2).
for compliance with building regulations when the
premises were constructed.

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In Scotland and in England and Wales, in consequence In the FRA, it is appropriate, in the case of blocks
of the fire at Grenfell Tower, both the building of flats, to consider whether, in the light of current
regulations and the guidance that supports the knowledge, the fire performance of cladding is
regulations were amended in relation to external wall likely to result in a fire hazard. This is extremely
construction and cladding, resulting in even greater difficult to assess within the scope of the FRA that
differences between requirements and guidance in can reasonably be expected to be carried out in
Scotland and those in England and Wales than already accordance with this PAS. This is because, without
existed. New building regulations and associated intrusive inspection (e.g. cutting out a section of the
guidance are not intended to apply retrospectively, wall or cladding construction), the wall build‑up,
but that does not preclude the need for rectification insulation and provision of cavity barriers are usually
of defects that resulted in non-compliance with the unknown; “as built” drawings, etc., are not always
regulations at the time of construction. sufficiently accurate to be relied upon solely for this.
Such destructive exposure is beyond the scope of
In England and Wales, compliance with the guidance in the FRA, and advice on the detailed design of the
Approved Document B [21] at the time of construction wall construction is beyond the capability of most
of the building is likely to satisfy the Fire Safety competent fire risk assessors. Even the nature of visible
Order [5]. However, since the fire at Grenfell Tower, it cladding might not be possible to determine without
has been found that, in respect of the fire performance cutting out a sample for laboratory examination or test.
of cladding and the provision of cavity barriers, a Accordingly, it is common for the FRA to exclude any
significant number of buildings failed, at the time detailed consideration of external wall construction
of construction, to meet the intent of Approved from its scope and to recommend, where appropriate,
Document B [21] and, hence, the requirements of that the design of external wall construction, and
building regulations in England and Wales. the hazard that might arise from it, is subject to fire
risk appraisal and assessment by suitably qualified
In addition, in December 2018, by an amendment to specialists.
Regulation 7 of the Building Regulations 2010 [22], in
England, a new requirement was introduced within The Fire Industry Association (FIA) strongly recommends
the Regulations. Under the amended Regulations, in to fire risk assessors [34] that, unless they feel confident
the case of buildings with a storey greater than 18 m to give definitive advice on the nature and fire hazard
above ground level, comprising, inter alia, a block of external wall construction, and have the appropriate
of flats, external walls and specified attachments qualifications, skills, knowledge and experience, they
(such as balconies and solar panels) are required to exclude assessment of the fire hazard of external wall
meet the criteria given in BS EN 13501-1:2007+A1 for construction and cladding from the scope of the FRAs
classification as A2-s1, d0 or A1. This new requirement that they carry out under the Fire Safety Order.
has applied to Wales from January 2020. At the time of The FIA advises that it is important that this is made
publication of this PAS, there are proposals to make a clear to the responsible person in the tender process and
similar change to the building regulations in Northern documents, the contract and the fire risk assessment.
Ireland. This is a prescriptive requirement, and does
not allow for alternative solutions, such as full-scale The FIA considers that, in most cases, a fire risk assessor
fire testing, desktop assessments or fire engineering will wish to exclude assessment of the fire performance
solutions. At the time of publication of this PAS, there of external wall construction and cladding from the
are no plans to make a similar amendment to the scope of the FRA carried out under the Fire Safety
building regulations in Scotland. Order. In such cases, it will then be necessary for the
FRA to include a recommendation that this matter be
In Scotland, in 2019, for domestic buildings, the subject to consideration by other suitably qualified and
guidance in the Domestic Technical Handbook [27] that competent specialists. It is anticipated that this further
supports building regulations was made considerably work will comprise a fire risk appraisal and assessment
more stringent in respect of the reaction to fire of in accordance with the recommendations of PAS 9980,
cladding and insulation materials exposed within any which is in preparation at the time of publication of
cavity behind the outer cladding. However, as the this current PAS.
Handbook comprises guidance, rather than prescriptive
requirements, alternative solutions, such as suitable Accordingly, the fire risk assessor needs to make
evidence from the large-scale fire test of BS 8414-1 a judgement as to whether it is appropriate to
or BS 8414-2, are acceptable means of demonstrating recommend further investigation of wall construction
compliance with the relevant mandatory building and cladding (usually by others) in the action plan.
standard in the Building (Scotland) Regulations 2004 This is the prerogative of the fire risk assessor, taking
(as amended) [33]. into account factors such as:

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1) the height of the building; the fire risk assessor will ignore unusual, but visually
2) the use of the building; obvious, material defects that place occupants at undue
risk. On the other hand, it is acknowledged that, in
3) information on approval of the building under
determining that the risk to life from fire spread over
relevant building regulations (if any);
external walls is not such as to warrant an appraisal and
4) appearance of external wall or cladding; assessment by a specialist, the fire risk assessor is not
5) information on external wall construction or deemed to be confirming conformity of external wall
cladding (e.g. in operation and maintenance construction to building regulations (past or present) or
manuals, or information handed over for the Fire Safety Order [5].
compliance with Regulation 38 of the Building
Regulations 2010 [22] in England and Wales or the In these circumstances, therefore, latent defects in
Fire safety design summary in Scotland [23]); construction might well continue to be unrevealed.
6) exposure of external walls or cladding to an Consultations with the National Fire Chiefs Council at
external fire; the time of drafting this PAS have confirmed that this
principle is accepted. It is simply the case that, in the
7) fire protection measures (e.g. compartmentation,
low‑risk circumstances described above, experience
automatic fire suppression, automatic fire
has shown, over many years and in some millions of
detection);
buildings, that the risk to loss of life from defects in
8) apparent quality of construction, or presence of external wall construction is so negligible as to be
building defects; and insignificant. It is, therefore, not unreasonable in these
9) anticipated evacuation time (if evacuation is cases for the fire risk assessor to assume conformity
necessary). to the building regulations that were current at the
time of construction, unless there is significant, visually
Only a few of these factors would, alone, enable a fire obvious, evidence to the contrary.
risk assessor to determine whether further investigation
is necessary. For example, a low-rise building, or a It is expected that the dutyholder will take
building with what is obviously a traditional masonry responsibility for making the fire risk assessor aware of
wall, is unlikely to warrant any further consideration. any known concerns regarding the fire performance
At the other extreme, a tower block that is obviously of external wall construction, or any alterations since
clad in an unknown form of metal cladding would the time of construction that might be detrimental
warrant a recommendation for further investigation, to the fire performance of external wall construction,
either by consideration of the other factors above, or including the installation of any new cladding,
by a further, more specialist investigation (which might fenestrations or attachments to the building.
be intrusive) by others. For many other situations,
the need for comment, advice, or recommendations In the case of cladding that is known to pose a
in the FRA is a matter for the judgement of the fire major hazard in the event of fire, there is likely to
risk assessor, based on training, experience and a be a need for the fire risk assessor to consider the
knowledge of current thinking, taking into account recommendation of interim measures.
guidance produced after the fire at Grenfell Tower
in 2017. Following the fire at Grenfell Tower, the Government
set up the Independent Expert Advisory Panel
It is, therefore, expected that fire risk assessors will (commonly known as “the Expert Panel”) to advise on
be judicious in their recommendations for a fire risk the risks of cladding materials in relation to external
appraisal and assessment of external wall construction fire spread over walls of high-rise residential buildings.
by a specialist within the action plan of an FRA. The advice of the Expert Panel to building owners
Unnecessary recommendations by fire risk assessors of multi-storey, multi-occupied residential buildings
for such appraisals and assessments, contrary to the in relation to external wall systems, spandrel panels,
guidance in this PAS, would make significant demand balconies, smoke control systems and fire doors has
on the scarce resources available for these appraisals been published as a single document by MHCLG [31].
and assessments, thereby diverting attention from
buildings in which the public might be at serious risk h) Automatic water-based suppression systems
and that actually do warrant them.
Automatic sprinkler installations are very effective
in the control of fire. The presence of an automatic
For avoidance of doubt, it is not suggested that, even in
water‑based suppression system, such as an automatic
the case of a building of a type that would, generically,
sprinkler installation, might therefore enhance life
normally be regarded as low risk (e.g. a four-storey
safety, reduce risk and limit the spread of fire from
block of flats of traditional masonry construction),

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its point of origin. Provision of sprinklers can allow a As noted above, other forms of water-based
reduction in the performance requirements of elements suppression system include water mist systems, which
of construction and compartmentation. In the case of can be appropriate in specific circumstances.
blocks of flats designed and managed in accordance
with BS 9991, the provision of sprinkler protection i) Other fire protection systems
within flats can permit increased travel distances within
Other fire protection facilities and systems that, if
common parts. Sprinklers also provide an additional
present or required, need to be taken into account in
layer of protection in the event of weaknesses in other
the FRA include:
measures, such as compartmentation.
1) smoke control systems and facilities;
Where suppression systems are part of the life safety 2) other localized fire suppression systems;
measures in any premises, or are taken into account 3) measures to assist the fire and rescue service,
as compensatory features for a reduction in other fire such as dry or wet fire mains (see 3.17 and 3.99
safety measures [see 5.3e)], this needs to be noted respectively), firefighters, fire-fighting or firemen’s
in the FRA, and procedures are necessary to manage lifts (see 3.59.3, 3.59.2 and 3.59.4 respectively) and
the resulting increase in risk that would occur if the firefighters’ switches for high voltage illuminated
suppression system were to be taken out of service, or signs; it is unusual for an FRA to recommend that
become defective, for any reason. firemen’s lifts be upgraded to the more modern
standards of firefighters or fire-fighting lifts, but
In Wales, sprinkler protection is required in all new consideration might be given to an element of
housing for compliance with the Building Regulations upgrading at the time of lift refurbishment or
2010 (as amended for Wales) [22]. In Scotland, sprinkler replacement; further guidance can be found
protection of flats in all new sheltered housing, and in BS 8899; and
in new blocks of flats greater than 18 m in height, is
4) evacuation alert systems for use by the fire and
necessary for compliance with the Building (Scotland)
rescue service in blocks of flats.
Regulations 2004 (as amended) [33]. From 2021, in
Scotland, the requirements for sprinkler protection
While such systems are not present in all premises, they
will apply to a wider range of housing at the time of
can play an important role in the safety of occupants in
construction, including all blocks of flats, regardless of
certain large or complex premises. Even if the objective
height, all new social housing, large HMOs and large
of such a system is property protection or assistance to
supported housing properties. In England, government
the fire and rescue service, it is still appropriate to note,
guidance (Approved Document B) [21] stipulates
and take account of, the system in the FRA.
sprinkler protection for flats in blocks of flats greater
than 11 m in height for compliance with the Building In some housing premises, smoke control systems can
Regulations 2010 [22]. In some cases, water mist can be be essential for protection of means of escape and/or
an acceptable alternative to a sprinkler system. assistance to the fire and rescue service. For example,
this is normally the case in all blocks of flats, sheltered
Sprinkler protection is particularly beneficial in
housing and extra care housing. Again, although an
specialized housing. In sheltered and extra care
engineering evaluation of a smoke control system
housing, in the event of fire, a properly designed,
is usually outside the scope of the FRA, the fire risk
installed and maintained system makes a death beyond
assessor needs to understand the manner in which
the flat of fire origin extremely unlikely, while also
the smoke control is intended to function, and it is
reducing the likelihood of a death in that flat, unless a
vital to ensure that there are adequate arrangements
person is directly involved in the fire (e.g. their clothes
for ongoing control, testing and maintenance of such
or bedding are ignited).
systems (see Clause 16).

While an engineering evaluation of an automatic


Localized fire suppression systems are not commonly
sprinkler system is not normally appropriate in the
installed in housing premises, although they can
course of the FRA, it is normally appropriate to confirm
feature in some circumstances, such as in certain flats
that there are no obvious shortcomings, such as
with open plan layouts. However, if present, it is
obstructions to sprinkler heads. It is also appropriate
appropriate to record their presence in the FRA and
to confirm that there are adequate arrangements
to take account of them, as they might contribute to
for testing and maintenance of the system so that
life safety. It is also appropriate to confirm that there
faults and major shortcomings can be identified
are arrangements for their testing and maintenance
(see Clause 16).
(see Clause 16).

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In most premises that require dry or wet fire mains, to assist the Scottish Fire and Rescue Service (in the
fire-fighting lifts or firefighters lifts, these are already same way that a rising main is such a facility). BS 8629
present. It is unusual for a need for such facilities recommends that evacuation alert systems for use by
first to be identified in the FRA, or for an FRA to the fire and rescue service are not to be integrated with
recommend retrofitting of such facilities in premises any other systems, such as fire detection and fire alarm
that were not provided with them at the time of systems and smoke control systems.
construction. These facilities are provided primarily to
assist the fire and rescue service. However, since safety It is likely that use of these systems will expand to other
of firefighters might depend on the correct operation parts of the UK and, possibly, even some existing blocks
of these facilities, it needs to be verified that there of flats. However, as in the case of other facilities for
are adequate arrangements for their testing and use by the fire and rescue service, it is unlikely that an
maintenance (see Clause 16); accordingly, the relevant FRA will identify a need for retrospective installation
fire safety legislation throughout the UK requires of such a system. In particular, as advised in BS 8629,
that these facilities are regularly maintained and are it is not appropriate to provide a system as a means
kept in an efficient state, efficient working order and of mitigating shortcomings in other fire protection
good repair. Also, where a stay put strategy applies, measures, such as compartmentation; deficiencies in
extinguishment of any fire by the fire and rescue compartmentation need either to be rectified or to
service can be essential to the safety of the strategy, so, result in a simultaneous evacuation strategy, supported
for example, in blocks of flats, measures that assist the by a suitable fire detection and fire alarm system.
fire and rescue service can be essential for the safety of
residents. 15.1 The FRA should include, as a minimum, details, or
a description, of:
j) Evacuation alert systems for use by the fire and a) means for detecting fire and giving warning to
rescue service occupants;
These systems can be installed in (normally high-rise) NOTE 1 In a purpose-built block of flats, there is
blocks of flats with a stay put strategy to enable the normally no fire detection and fire alarm system in
fire and rescue service to initiate, via control equipment the common parts, nor is such a system normally
at the fire and rescue service entry level, an audible recommended. (In some modern, complex or larger
evacuation alert signal in flats on a selected storey(s) developments, there might be public or ancillary
of the building (or a part of a storey or the entire areas which are served by a fire detection and fire
building). The concept is not entirely new. (Such a alarm system, in which case PAS 79-1 might apply.)
system was recommended for a high-rise block of flats Care is necessary not to confuse fire detection
in the North of England as long ago as 2005.) However, provided as part of a smoke control system, which
use of such systems was, until 2019, extremely rare and does not normally incorporate fire alarm sounders,
specific to a particular fire engineering solution. with a fire alarm system. Fire detection within the
flats is only considered in a Type 3 or Type 4 FRA
In the Grenfell Tower fire in 2017, as Grenfell Tower for purpose-built blocks of flats, and in FRAs for
was designed on the basis of a stay put strategy, there other forms of housing, comprising most sheltered
were no facilities whereby the fire and rescue service housing, extra care housing, supported housing and
could effectively initiate a simultaneous evacuation of HMOs.
all residents. In response to this fire, by amendment of b) means of escape from the premises. In some
the Domestic Technical Handbook [27] that supports housing premises, such as supported housing with
the Building (Scotland) Regulations 2004 a simultaneous evacuation strategy, consideration
(as amended) [33], Scottish Government have, from should be given to means of escape and
1 October 2019, specified that, for compliance with arrangements for evacuation of disabled people;
these Regulations, such systems ought to be installed in other forms of housing, such as general needs
in all new blocks of flats with a storey greater than blocks of flats, it is not normally practicable to make
18 m in height as a facility to assist the Scottish Fire arrangements for assistance to disabled people
and Rescue Service. by staff on the premises, as normally no staff are
present in the building for this purpose;
It is important that these systems are not confused with
NOTE 2 A short description of the means of escape
fire alarm systems. In Scotland, for the purpose of the
is of value in subsequent FRAs, in that it can enable
Building (Scotland) Regulations 2004 (as amended) [33],
changes since the time of the previous FRA to be
these systems are not part of the requirements for fire
identified.
alarm systems, but are part of the measures necessary

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c) fire safety signs and notices; 15.5 In a Type 3 and Type 4 FRA, the means for warning
NOTE 3 In many housing premises, no signs might any identified Deaf or hard of hearing occupants in the
be necessary, but there might be a need for fire event of a fire in their own accommodation should be
procedure/fire action notices. addressed.
d) emergency escape lighting;
15.6 Means of escape should be assessed taking into
e) means to limit spread and development of fire; account the factors discussed in Annex C.
f) any obvious concerns regarding the hazard of fire
spread over external walls; 15.7 It should be determined whether arrangements
g) means for fighting fire; for evacuation of any disabled or other occupants are
necessary and practicable to implement in the event of
h) other relevant fire protection systems and
fire. In sheltered and extra care housing, it should be
equipment; and
confirmed in the FRA that there is a secure premises
i) facilities to assist firefighters. information box that contains relevant information in
relation to disabled residents, including PEEPs for each
15.2 The extent to which fire protection measures are disabled resident (unless this information is held by
necessary, and the adequacy of existing measures, staff who are permanently on the premises).
should be determined, and shortcomings in such
NOTE Further guidance is given in the
measures should be addressed within the action plan
LGA guide [1] and equivalent guidance produced by
(see Clause 19).
Scottish Government [2]. Consideration of this matter
NOTE 1 It is always necessary for there to be adequate is likely to be appropriate in the case of certain types
means of escape in the event of fire. of specialized housing, such as supported housing.
NOTE 2 The FRA does not normally involve a detailed Further guidance is given in the NFCC guide [3] and the
engineering evaluation of fire protection systems Northern Ireland HMO fire safety guide [26].
and equipment, but a recommendation for such an
evaluation might be included in the action plan if there 15.8 In every FRA, a judgement should be made as to
are doubts about the adequacy of the system. whether there is a need for emergency escape lighting.
NOTE 3 A Type 1 or Type 3 FRA, the former of which is If emergency escape lighting is considered necessary,
the default FRA for compliance with the relevant fire subjective judgement should be made to the adequacy
safety legislation (in premises that fall within the scope of any existing emergency escape lighting.
of the legislation), does not involve opening up the
structure of the premises, such as cutting holes in, or 15.9 It should be determined whether there is a need
removal of, sections of walls, ceilings partitions, etc. for fire safety signs, particularly those associated with
If a dutyholder requires such an “intrusive” inspection, assistance in use of escape routes. The adequacy of
this would involve a Type 2 or Type 4 FRA, and a existing signs should be determined.
requirement for this type of FRA would need to be
made clear to the fire risk assessor. However, such an 15.10 The need for, and the adequacy of the type,
inspection can be recommended in the action plan of number and siting of, manual firefighting appliances
the FRA, subject to justification based on evidence of should be determined.
probable shortcomings in the compartmentation. NOTE Normally, fire extinguishers are unnecessary in
the common parts of blocks of flats, sheltered housing
15.3 The purpose of assessing the fire protection and extra care housing, but extinguishers are normally
measures described in 15.1 is to determine their necessary in certain other areas of these premises
contribution to safety of occupants in the event of fire. (e.g. plant rooms).
However, none of these measures should be assessed in
total isolation of the other measures; account should be 15.11 The adequacy of fire stopping, the flammability
taken of the effect of the entire package of measures of linings and, where appropriate, the flammability of
(including relevant managerial arrangements) on the furniture and furnishings should be addressed so far as
consequences of fire to life safety. is reasonably practicable.
NOTE It is not normally practicable to carry out a
15.4 The role, appropriate extent, and the cause complete review of fire stopping in premises. In a
and effect strategy, for automatic fire detection and Type 1 and Type 3 FRA, reliance on a visual inspection
fire alarm systems, and their adequacy, should be of a sample of readily accessible areas is normally
addressed. adequate. More intrusive inspection is limited to Type 2
and Type 4 FRAs.

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15.12 The FRA should take account of the potential for


means of escape to be compromised by ventilation and
air conditioning systems.
NOTE Although a detailed evaluation of the fire
protection measures incorporated in such systems
might not be practicable in the course of an FRA, where
the risk to life from fire is high it might be necessary to
recommend further investigation within the action plan
(see Clause 19) into the fire strategy and the cause and
effect of the fire detection and fire alarm system.

15.13 The FRA should take account of all other fire


protection systems that might be present, including
automatic suppression systems, smoke control systems,
localized fire suppression systems, dry or wet fire mains,
lifts for use by the fire and rescue service, firefighters’
switches and evacuation alert systems for use by the
fire and rescue service. In the case of smoke control
systems, fire risk assessors should ensure that they
understand the objective of the system and verify, so
far as practicable, that the original design concept
has not been undermined (e.g. by alterations to the
premises).
NOTE This does not imply that fire risk assessors need
verify the design calculations for smoke control systems,
as this would not be expected to be within the scope
of their expertise. However, where there is reason to
suspect that the design of the system is not adequate,
further, separate evaluation could be recommended in
the FRA.

15.14 Consideration should be given to the external


wall construction and, in particular, cladding. Although
it might be acceptable to assume that the wall and any
cladding satisfied the relevant building regulations
at the time of construction of the building, the fire
risk assessor should be alert to any situation in which
there is good reason to suspect that the original
construction, or subsequent overcladding, failed to
conform to the building regulations that were current
at the time of construction. In such cases, there should
be further investigation, which might necessitate a
recommendation for this in the action plan.
NOTE Other than in the case of construction that is
likely to pose minimal risk, such as traditional masonry
construction, any fire risk appraisal and assessment of
external wall construction or cladding is likely to need
the skills of a specialist as it is beyond the competence
of a typical fire risk assessor.

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16 Assessment of fire safety management

COMMENTARY ON CLAUSE 16 6) arrangements for routine inspections of the


premises and their fire precautions or for more
At the time of publication of this PAS, the government formal fire audits (see 3.26);
in England and Wales plan to make changes to fire 7) cooperation and coordination between different
safety legislation, particularly in the light of the dutyholders;
recommendations of Phase 1 of the Public Inquiry
8) training of staff (if any) and fire drills (see 3.28);
into the Grenfell Tower fire. It is likely that many such
changes will relate to management of fire safety in NOTE 2 In most housing premises, fire drills are
blocks of flats. It is important that fire risk assessors unnecessary and inappropriate.
monitor, and react to, any such changes as part of their 9) provision of information to third parties;
continued professional development. 10) testing and maintenance of fire protection
systems and equipment;
The following considerations are relevant to this clause.
11) documentation of fire safety arrangements and
a) General keeping appropriate records;
In the FRA, fire safety management (see 3.45) needs to 12) implementation of the action plan’s
be regarded as of equal importance to fire protection recommendations; and
measures. In its broadest sense, fire safety management 13) review of the FRA at appropriate intervals.
includes certain policies and procedures designed
Points 1) to 11) are discussed in the sections of
to prevent the occurrence of fire by eliminating or
commentary that follow. Point 12) is discussed in
controlling fire hazards. However, most of these
Clause 19, and point 13) is discussed in Clause 20.
aspects of fire safety management have already been
It is important that matters in the paragraphs that
considered in Clause 13.
follow are properly considered in the FRA and that
fire safety management is taken into account in the
Fire safety management also includes:
subjective judgement of overall fire risk (see Clause 18).
1) designated responsibility for fire safety in the Recommendations for fire safety management of
premises; residential premises can be found in BS 9991:2015,
2) access to suitable advice on the requirements of Section 9. More detailed guidance can be found
fire safety legislation; in references [1], [2], [3], [4], [6], [12], [16] and [26]
3) procedures for people to follow in the event (as appropriate) in the Bibliography within this PAS.
of fire, including any people with special BS 9997 provides requirements for an organizational
responsibilities; fire risk management system, and can be used to audit
4) in certain housing premises, nomination of people fire risk management within an organization.
to respond to fire and, where appropriate, to b) Responsibility for fire safety
assist with evacuation; Although legislation does not demand that a specific,
NOTE 1 In most housing premises, there are no named person be responsible for fire safety within
staff to assist residents with evacuation, nor is this particular housing premises, it is of advantage to
required for compliance with the relevant fire confirm, in the FRA, that within the organization
safety legislation; the main exception is certain there is someone who, in at least an administrative
supported housing premises with a simultaneous sense, is responsible for fire safety within the premises.
evacuation strategy, in which residents might The intention is not to provide a legal interpretation
depend on staff to assist them with evacuation. of responsibility, but to reflect the managerial
5) arrangements for liaison with the fire and rescue arrangements in place at the time of the FRA.
service, both in respect of planning for fire and, The person in question might, or might not, have a
in premises with 24 h staffing, at the time of any legal responsibility for breaches of legislation, etc.
fire;

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According to the manner in which the organization 3) in properties with a fire alarm system, the
is structured, the person named in this section of the importance of operating the system immediately on
FRA might be a director, building manager, facilities discovery of fire;
manager, health and safety manager, fire safety 4) in properties with a fire alarm system or an
manager (see 3.46), estates manager, etc. The person evacuation alert system for use by the fire and
might or might not work within the premises, and the rescue service, the importance of evacuating the
responsibility could even be shared by two or more premises immediately when an alarm signal is given;
people. It is, however, important in the management of
5) any special arrangements for evacuation of disabled
any organization that someone is, and accepts that they
occupants;
are, responsible for fire safety, particularly in the case
of premises in which there are multiple dutyholders. 6) in premises with staff, the policy on firefighting by
employees;
c) Access to advice
7) the summoning of the fire and rescue service;
NOTE 3 Attention is drawn to the requirements of the
8) in premises with a simultaneous evacuation
relevant fire safety legislation for the appointment or
strategy, the location of the evacuation assembly
nomination of one or more “competent persons” to
point(s); and
assist in compliance with that legislation, and to the
definition of “competent person” given in the relevant 9) the importance of not attempting to re-enter the
fire safety legislation. premises after evacuation until instructed to do so
by the fire and rescue service.
The “competent person” required by the relevant fire NOTE 4 In cases of false alarms that the fire and rescue
safety legislation might, or might not, be the person service do not attend, the decision to re-enter the
responsible for fire safety, to which reference is made premises needs to be taken by the person in charge.
in item b) of the Commentary on Clause 16. However,
the two are often different, since the person having In housing premises with staff, there might be a need
responsibility for fire safety might be a premises for dedicated procedures for any staff with special
manager or scheme manager, while the “competent duties in the event of fire. These could include, for
person” might be a trained professional in the field of example, staff in supported housing, a scheme manager
fire safety or health and safety, often based in a remote (when present) in sheltered housing, or care staff in
location, such as a group head office. extra care housing.
e) Nomination of people with special duties in the
The fire safety policy needs to set out the
event of fire
organizational structure and indicate the sources of
competent assistance available to the dutyholder. In carrying out the FRA, there is a need to ensure that
Often, organizations are able to appoint one or more any staff (as well as all residents) are aware of the
of their own employees for this purpose, while large means for summoning the fire and rescue service in the
organizations might appoint whole departments with event of fire. The arrangements are expected to form
specific health and safety responsibilities, including part of the fire procedures for the premises [see item d)
specialists in various matters, such as fire safety. of the Commentary on Clause 16], but it might be the
Equally, if consultants are used for advice, it is case that summoning the fire and rescue service is the
necessary for their activities to be coordinated by the responsibility of a nominated post-holder, such as care
organization, since external consultants are usually staff in supported and extra care housing. Even if there
appointed in an advisory capacity only, and their are means for automatic transmission of fire alarm
appointment does not absolve the organization from signals to an alarm receiving centre, defined procedures
its responsibilities (see Clause 6). are still needed (particularly where staff are present)
for summoning the fire and rescue service by means of
d) Fire procedures the public emergency call system.
In the course of the FRA, there is a need to ensure that
there are formal, documented procedures for people to
follow in the event of fire, and that these procedures
are adequate. Adequate procedures normally address:
1) actions to follow on discovery of fire;
2) in properties with a fire alarm system, actions to
follow on hearing the fire alarm signal;

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In premises with 24 h staffing and a simultaneous and there is no storage in escape routes that need to
evacuation strategy, the fire risk assessor also needs to remain relatively sterile. Sometimes these matters are
investigate the adequacy of any defined arrangements addressed in the course of health and safety inspections
for ensuring that the premises are evacuated, and or more specific fire audits. Often, more frequent day-
to ensure there is suitable control, coordination and to-day inspections, of a basic nature, can be carried
monitoring of evacuation procedures. Information on out by, for example, a scheme manager in sheltered
the status of the evacuation is of importance to the fire housing or the caretaker of a block of flats (subject
and rescue service when they arrive at the premises. to very simple instruction or training). It is important
NOTE 5 Attention is drawn to the requirements of that adequate procedures are in place to enable
the relevant fire safety legislation regarding the any deficiencies identified in the course of routine
nomination of people to assist in evacuation. inspections to be reported and subsequently addressed
(e.g. within the scope of a maintenance schedule).
In supported housing with a simultaneous evacuation
strategy, if residents need assistance to evacuate, it h) Staff training and fire drills
is appropriate to consider, within the FRA, whether Most housing premises do not have 24 h staff, but
sufficient levels of staff are present to ensure the safety it is necessary to provide fire safety training to any
of residents during both day and night. This normally staff (even if working part time in the premises) who
necessitates discussions with the care provider. are present. This would particularly apply to scheme
NOTE 6 Arrangements whereby staff are required to managers in sheltered housing, care staff in extra
evacuate one or more residents from the property and care housing, and care and support staff in sheltered
then re-enter to assist further residents are unlikely to housing.
be adequate.
However, fire drills are not normally carried out in
f) Liaison with the fire and rescue service housing premises, even if there is a simultaneous
evacuation strategy. Nevertheless, drills might be of
In large and complex premises, it is important that
assistance in some supported housing, if they would
there are arrangements for local fire and rescue service
assist in imparting an understanding of fire procedures
crews to familiarize themselves with the premises
to residents who might have difficulty in this respect
and with, for example, the facilities for firefighting
because of cognitive difficulties.
and smoke control. While there are legislative
requirements imposed on fire and rescue services in NOTE 7 Attention is drawn to the requirements of the
this respect, it can be beneficial for dutyholders to relevant fire safety legislation for adequate training for
be proactive in inviting the fire and rescue service to employees.
carry out familiarization visits. In some such premises,
there might be a need for predetermining emergency If fire safety induction training (see 3.44) of any staff
procedures with the fire and rescue service. In addition, is appropriate, fire safety refresher training (see 3.50)
it is important that the fire procedures for the premises needs to be given periodically. The frequency of
include arrangements for summoning of the fire and refresher training needs to take into account the
rescue service in the event of fire and meeting the fire turnover of staff, the complexity of the premises and
and rescue service on arrival. their fire procedures, and the fire risk. There might be
a need to provide additional, or dedicated, training for
people who have special responsibilities in the event of
g) Routine inspections
fire.
The FRA is somewhat similar to the MOT inspection
of a car, in that it reflects the conditions found by an i) Provision of information for third parties
assessor at a particular point in time. There is, however, Where the employees of third parties work in the
a need to ensure that, on a more routine basis, there premises of a dutyholder, the dutyholder needs to
are means for detecting deficiencies in fire precautions. ensure that adequate information on fire procedures
Accordingly, it is appropriate for the fire risk assessor to and relevant fire precautions is passed on to their
investigate arrangements for routine inspections of the employer, and that the employees have been given
fire precautions. the relevant information. Such third parties include
contractors working on the premises and contract
Such inspections need little or no specialist knowledge, cleaners.
but can make a major contribution towards the NOTE 8 Attention is drawn to the requirements of
maintenance of adequate fire precautions by the relevant fire safety legislation for the provision
checking that, for example, means of escape remain of information to third parties who work, or employ
unobstructed, self-closing fire doors operate correctly, people to work, on the premises.
fire exit doors that are not in normal use open easily

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j) Testing and maintenance of fire protection measures l) Cooperation and coordination between dutyholders
The fire risk assessor needs to ensure that there are Where two or more organizations share responsibility
adequate arrangements for testing and maintenance for fire safety, the safety of all occupants can be
of all fire protection measures. There is also a need achieved only if the organizations cooperate with one
to ensure that the workplace itself is adequately another and coordinate their fire safety measures.
maintained in order to avoid certain fire hazards. It is not uncommon for there to be multiple
NOTE 9 Attention is drawn to the requirements of dutyholders in, for example, supported housing. For
the relevant fire safety legislation for testing and example, these might comprise a landlord, a housing
maintenance of fire precautions required by that association, which leases the property, and a care
legislation, and for testing and maintenance of provider; the local authority that places persons in the
facilities, systems and equipment required under other property might, arguably, be a further dutyholder. In
legislation (e.g. building regulations) for the use by, or such cases, it is essential that there is a record of the
safety of, firefighters. Examples of the latter facilities agreed responsibilities of each dutyholder and that
include rising mains, fire-fighting lifts and evacuation this is checked for adequacy and accuracy in the FRA
alert systems for use by the fire and rescue service. [see also item l) of the Commentary on Clause 16]. For
Requirements and recommendations for testing and further information, see references [6], [12] and [16] in
maintenance of systems are given in the relevant British the Bibliography within this PAS.
Standards for the particular systems and equipment.
Annex F contains a model matrix for recording the
responsibilities for fire safety measures in those
k) Record keeping
specialized housing premises in which there are
The relevant fire safety legislation requires appropriate multiple dutyholders under the relevant fire safety
arrangements to be put in place for the effective legislation. The purpose of the matrix is to ensure that
planning, organization, control, monitoring and the responsibilities of each dutyholder are clear to all
review of the measures that the FRA identifies as being dutyholders and that none of these responsibilities are
necessary for compliance with that legislation. Other overlooked. The matrix can form part of the fire safety
than in the case of certain small businesses, it is a legal manual (see 3.47) and can be regarded as part of the
requirement for these arrangements to be recorded. record of the fire safety arrangements that is required
Therefore, there is a need for a fire safety manual for by the relevant fire safety legislation [see item k) of the
the premises (see 3.47). Commentary on Clause 16].

It is not necessarily specifically required that records In England and Wales, dutyholders in a block of flats
of training, inspection, testing, maintenance, etc., can include those occupying domestic premises to
are kept. Nevertheless, such records are an important which the relevant fire safety legislation does not
means of demonstrating, if required, that all legislative generally apply (i.e. the flats); the safety of all persons
obligations have been satisfied. It is, therefore, relevant in the block might rely on fire protection measures in
for the fire risk assessor to consider any records the individual flats. This is particularly true of the flat
that exist and to make recommendations, where entrance doors, which need to be fire-resisting and
appropriate, for keeping of suitable records. These self-closing. Commonly, under a lease, the doors are
records can also be important in demonstrating that demised to leaseholders, making them dutyholders
there have been no breaches of good practice that under the relevant fire safety legislation. Where,
could result in litigation in the event of injury to an uncommonly, there is a simultaneous evacuation
occupant of the premises in the event of fire. strategy, fire detectors in the dwellings are likely to be
part of the measures required under the Fire Safety
Where there is a fire detection and fire alarm system, Order [5].
it is also good practice (though not required by the
relevant fire safety legislation) to maintain records of In all housing, it is important that housing providers
false alarms. Dutyholders might be unaware of the and other relevant dutyholders engage and
value of keeping these records. It is therefore beneficial communicate with residents in relation to fire safety;
for fire risk assessors to remind dutyholders of the this is particularly important in blocks of flats, sheltered
importance of such records, particularly in buildings housing and extra care housing. In these buildings,
with a large number of smoke detectors. This can it is important that residents are provided with the
enable unacceptable rates of false alarms, and the need following information:
for action in respect of these, to be identified.
1) measures to prevent fire in their own flat and in
the common parts;

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2) the importance of maintaining their block secure 16.3 In the course of the FRA, the following matters
and being vigilant for deliberate fire setting; should be taken into account. Any shortcomings in
3) the need to avoid the storage of petrol, bottled these matters should be identified in the documented
gas and other dangerous substances in their flats, FRA and should be addressed in the action plan
on their balcony or in shared areas; (see Clause 19):
4) action in the event of fire; a) the fire procedures, including procedures for any
people with special responsibilities in the event of
5) the means of escape from their flats and the
fire;
building;
b) any arrangements for summoning the fire and
6) in buildings with a stay put strategy, a clear
rescue service in the event of fire;
explanation of what this strategy entails;
c) information on any staff who respond to a fire in
7) the responsibility of residents to safeguard
the premises;
communal escape routes;
d) information on any people who assist with
8) the policy regarding housekeeping in the common
evacuation (e.g. of disabled people);
parts;
e) any arrangements for liaison with the fire and
9) the importance of not carrying out alterations
rescue service;
that could be detrimental to fire safety;
f) arrangements for routine inspections of the
10) the importance of routine testing of smoke
premises and their fire precautions;
alarms;
g) in the case of premises with multiple dutyholders
11) the importance of avoiding obstruction of fire and
under the relevant fire safety legislation,
rescue service access to the block and to fire main
arrangements for cooperation and coordination
inlets and landing valves (where provided); and
between different dutyholders;
12) means for reporting defects in fire safety measures
h) training of any staff;
within their flat and the common parts.
i) fire drills (though these are not normally necessary
Residents’ handbooks are one means of communicating or appropriate);
this information, which can also be included on any j) arrangements for engagement with residents to
website of the housing provider. Notices within the provide relevant fire safety information;
building and leafleting of residents can also assist in k) provision of information to third parties;
keeping the relevant information fresh in the minds of
l) testing and maintenance of fire protection systems
residents. It is important that, for those residents for
and equipment by a competent person (including
whom English is not their first language, written advice
systems and equipment installed for use by, or for
is presented in alternative languages.
the safety of, firefighters);
Other means of communicating information to m) maintenance of the premises;
residents include periodic meetings. At any meeting n) records of false alarm information as described in
with residents, there is an opportunity to remind them BS 5839-6:2019, 27.2; and
of fire procedures, fire prevention measures, o) other appropriate records, including, normally, a
the importance of provision, and testing, of smoke fire safety manual.
alarms, etc. Engagement with residents needs to
facilitate residents’ voices to enable expression of any 16.4 Where, in specialized housing, there are multiple
concerns in respect of fire safety. This also provides dutyholders under the relevant fire safety legislation,
an opportunity to identify the need for support to the fire risk assessor should check that a matrix of
residents from other agencies. Such engagement needs responsibilities (see Annex F) has been completed,
the cooperation of occupants, who need to contribute remains accurate and is working effectively.
to a dialogue with dutyholders.

16.1 The FRA should record the name(s) or post(s) of


the person(s) responsible for fire safety in the premises.

16.2 It should be verified that there are arrangements


for obtaining competent advice on the requirements of
fire safety legislation. The source of such advice should
be recorded in the documented FRA (see Clause 10).

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17 Assessment of likely consequences of fire

COMMENTARY ON CLAUSE 17 The predetermined categories of likely consequences


of fire may be described in the form of words, such as
After all fire protection measures and all aspects of “slight harm”, “moderate harm” and “extreme harm”,
fire safety management have been assessed, the fire provided these terms are defined, or in the form of
risk assessor is in a position to make an assessment numbers (e.g. 1, 2 and 3), but there is a need for at
of the likely consequences of fire, taking account least three categories. However, if likely consequences
of the factors concerning the premises and their are expressed in the form of numbers, care is necessary
occupants (see Clause 12). As well as consideration to ensure that it is not implied, for instance, that a
of fire protection measures and matters such as fire score for likely consequences of “2” indicates that fire
procedures, account needs to be taken of human is twice as likely to result in casualties compared to a
behaviour. It is not, for example, appropriate for the score of “1”.
FRA to assume perfection in the response of people to
fire alarm signals, particularly in the case of specialized There is no upper limit to the number of categories of
housing. Account needs to be taken of the manner in likely consequences that can be adopted in the FRA
which the known occupants of the premises are likely process. However, if too many categories are adopted,
to behave in the event of fire. the distinctions between categories are meaningless.
Moreover, if the same FRA process is then applied to
It would be possible, in theory, to associate different numerous different premises (e.g. within the estate of
consequences of fire with different fire scenarios arising a single housing provider), particularly by different fire
from each of the fire hazards identified in the fire risk assessors, assessments of the likely consequences
hazard identification step of the FRA (see Clause 13). of fire are likely to be inconsistent, and the benefits
However, this would make the FRA process of comparing fire risk in different premises (e.g. for
unnecessarily complex and unduly lengthy. Usually, it the purpose of prioritizing improvements on a
is sufficient to assess the most likely consequences of a building‑by‑building basis) are then lost.
fire in the premises, taking into account the range of
fire scenarios that can reasonably be anticipated, and One common practice for the assessment of fire risk
assuming that normally only one fire occurs at any one (see Clause 18) is for fire risk to be determined by
time (i.e. generally discounting multiple seats of fire). means of combining the assessment of the likelihood
of fire and the assessment of the likely consequences of
The assessment of likely consequences needs to take fire, using a matrix. It is this method that is suggested
into account the extent of injury that would occur to in this PAS. Where such an approach is adopted, it is
occupants in anticipated scenarios, and the number of helpful to use the same number of categories for both
occupants likely to be affected. Consequences are more likelihood of fire and likely consequences of fire.
serious if a greater number of occupants are affected.
Equally, serious consequences include, for example, a In assessing the likely consequences of fire, for the
situation in which there is a high likelihood that a small purpose of carrying out the FRA to which this PAS
number of occupants will be subject to serious injury in relates, it is not normally necessary, or appropriate, to
the event of fire. carry out calculations of the type used in the practice
of fire safety engineering (see 3.43). However, the
The likely consequences of fire need not, and principles of fire safety engineering may be used, in a
usually cannot, be expressed in a statistical manner subjective manner, to assess the likely consequences of
(e.g. probability of death or serious injury). All that is fire, using the principle of “timelines” that forms the
required is a subjective judgement that classifies likely basis of fire safety engineering (see Figure 3).
consequences of fire into one of several predetermined
categories. Since the assessment of these factors is In Figure 3, which is a simplified version of a similar
subjective, the use of numbers to express the likely figure in BS 7974:2019, for premises with simultaneous
consequences of fire does not confer any greater evacuation, the RSET (see 3.80) is broken down into a
accuracy to the assessment of fire risk. number of components, namely:
a) the time between ignition of a fire and detection of
the fire (whether by occupants or by an automatic
fire detection system);

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b) the time between detection and the giving of the then be taken of fire precautions (whether existing or
alarm warning to relevant occupants; proposed in the action plan) that extend the ASET
c) the time between the giving of the alarm warning (e.g. measures to extinguish or suppress the fire or to
to relevant occupants and the recognition by these control smoke).
occupants that the alarm warning is a warning of
fire; 17.1 In the process of every FRA, an assessment should
be made of the likely consequences of fire.
d) the time between this recognition and the response
by occupants (i.e. the time to begin evacuation); NOTE It is usual and acceptable for the likely
and consequences of fire to be expressed subjectively
(e.g. “slight harm”, “moderate harm” or “extreme
e) the time between response and completion of
harm”).
evacuation of occupants to a place of ultimate
safety.
17.2 If, in the FRA methodology adopted, a matrix is
used to combine the likelihood of fire and the likely
The RSET, so derived, is then compared with the ASET
consequences of fire in order to determine the fire
(see 3.6). For safe evacuation of occupants, the ASET
risk, the number of predetermined categories of likely
needs to be significantly longer than the RSET. In the
consequences of fire should be the same as the number
FRA, Figure 3 is particularly useful in forming the
of predetermined categories of likelihood of fire
basis for an analytical approach to situations in which
(see Clause 14).
evacuation, when required, might be prolonged as a
result of the characteristics of residents. Account can

Figure 3 – Example of timeline comparison between ASET and RSET

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18 Assessment of fire risk

COMMENTARY ON CLAUSE 18 The advantage of this approach is that it tends to


result in relatively consistent assessments of risk (and,
It is innate to the process of carrying out an FRA that hence, fire risk) by different risk assessors; the risk
there be an assessment of fire risk, which it is then assessor need select from the matrix only one of three
appropriate to document. The assessment of fire levels of likelihood and one of three levels of likely
risk enables the (usually subjectively based) fire risk consequences, but can derive thereby any one of five
in one premises to be compared with the fire risk in levels of fire risk.
other premises (e.g. within the single estate of one
organization), so identifying those premises in greatest 18.1 In the process of every FRA, an assessment should
need of attention. Even applied to single premises be made of the fire risk in the premises.
in isolation, the assessment of fire risk can provide a NOTE It is usual and acceptable for the fire risk
useful descriptor that imparts a sense of the magnitude to be expressed in terms of one of a number of
of fire risk. predetermined categories of risk (e.g. “trivial”,
“tolerable”, “moderate”, “substantial” or
The categories for classification of fire risk are derived “intolerable”).
from those used to determine the likelihood and likely
consequences of fire (see Clause 14 and Clause 17). 18.2 If, in the FRA methodology adopted, fire risk is
Whereas it is normally sufficient to classify likelihood expressed in terms of one of several predetermined
of fire, or likely consequences of fire, into one of categories, there should be at least five predetermined
three predetermined categories, a greater number categories.
of categories of fire risk is normally appropriate in
order to cater for the range of levels of fire risk that 18.3 The FRA methodology adopted should be such
can occur. Thus, a minimum of five predetermined that there is a transparent means for combining the
categories of fire risk is normally appropriate. likelihood of fire and the likely consequences of fire to
derive the fire risk.
The category of fire risk for any premises can be
NOTE Table 1 shows an example matrix of categories
determined by combination of the likelihood of fire
of likelihood and consequences that can be adopted in
and the likely consequences of fire, using a matrix; this
assessment of fire risk.
is a method of risk assessment commonly adopted in
the field of health and safety.

Table 1 – An example of a simple risk level estimator

Likelihood of fire Classification of fire risk


Likely consequences of fire
Slight harm Moderate harm Extreme harm
Low Trivial risk Tolerable risk Moderate risk
Medium Tolerable risk Moderate risk Substantial risk
High Moderate risk Substantial risk Intolerable risk

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19 Formulation of an action plan

COMMENTARY ON CLAUSE 19 The fire precautions proposed ought to be the most


cost-effective available; often a single fire safety
The outcome, and indeed the principal raison d’être, objective (see 3.48) can be satisfied by a variety of
of the FRA is the action plan. The action plan comprises measures.
recommendations that are intended to ensure that the
fire risk is reduced to, or maintained at, a tolerable The practicality of fire precautions, and their
level (see 3.93). Even if the fire risk is already tolerable, acceptability to residents, are also essential. There
there is often a need to make recommendations in is no point in installing self-closing fire doors in the
the action plan, often involving low cost or changes in corridors of sheltered housing if discussion with those
managerial arrangements, to address minor deficiencies who best know the residents would have revealed that
in fire precautions. they would be such an impediment to older or disabled
residents that they would always be wedged in the
In formulating an action plan for premises in which open position. Equally, if this is clear from discussion
the fire risk has been assessed as unacceptably high, with those who manage the premises, the problem can
the subjective but analytical approach to fire risk be pre-empted by installing fire doors that are held
assessment permits backtracking to determine whether, open by automatic door release mechanisms, which
in effect, the problem arises from inadequate fire release the self-closing doors on operation of smoke
prevention (i.e. inadequate means for control or detectors in the corridor.
elimination of fire hazards), inadequate fire protection
(e.g. unsatisfactory means of escape or fire warning It is normally appropriate to allocate priorities to each
systems), shortcomings in fire safety management, measure recommended in the action plan, to reflect
or a combination of these. the urgency of the measure, as determined in the FRA.
(This might be unnecessary if, for example, most of the
The action plan is an inventory of actions, normally recommended measures are minor in nature and will
prioritized and time-constrained, to devise, maintain be implemented in the short term in any case.)
or improve controls. Where appropriate, the inventory
includes measures to eliminate or control hazards If prioritization is appropriate, it is often helpful to
(e.g. better separation of combustible materials from have a scheme of prioritization that is suitable for the
ignition sources). A blend of physical and procedural way in which the organization operates and projects
controls is often necessary. are planned. There is no right or wrong scheme of
prioritization, but, whatever scheme is adopted, it
The adequacy of the action plan needs to be tested, needs to be simple to understand, facilitate consistent
at least in the mind of the fire risk assessor, before it application and be relatively unambiguous as far as
is finalized. At that stage, it is appropriate to ask the allocation of priorities is concerned. This suggests that
following questions. it is appropriate for there to be no more than three or
a) Will the revised controls lead to tolerable fire risk four priorities.
levels?
A simple scheme might have only four priorities, such as:
b) Could any of the recommended actions create new
hazards to health and safety? 1) immediate (to be implemented as soon as possible),
including, where relevant, interim measures
c) Have the most cost-effective solutions been chosen?
necessary to ensure the safety of occupants until
d) What will residents affected think about the need permanent measures can be implemented;
for, and practicality of, the revised fire precautions?
2) short term (to be implemented within, perhaps,
e) Will the revised fire precautions be adopted and three months);
maintained in practice and not ignored in the face
3) medium term (to be implemented within, perhaps,
of, for example, normal use of the premises?
three to six months); and
All of these questions have a relevance to any action 4) long term (to be implemented as and when
plan, the objective of which is to achieve tolerable the opportunity arises, such as at the time of
risk, but without the creation of new hazards. replacement of a fire door or refurbishment of
premises).

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Many other systems of prioritization are possible. if they are carried out by more than one fire risk
For example, priorities might distinguish between assessor.
matters that constitute breaches of legislation and
those that do not. 19.1 Every documented FRA should incorporate an
NOTE Under the relevant fire safety legislation, breach action plan. If the fire risk and existing fire precautions
of the requirements of the legislation in respect of fire are such that no recommendations for improvements
precautions constitutes a criminal offence only if the are necessary, it should be explicit within the FRA that,
breach results in the risk of serious injury or death of in the opinion of the fire risk assessor, the only actions
one or more persons who are lawfully on the premises, necessary are those to maintain the existing standard of
or in the immediate vicinity of the premises, in the fire precautions.
event of fire. NOTE The action plan is sometimes, more simply,
described as “recommendations”, particularly when
Therefore, for example, a possible scheme of the FRA is carried out by a third-party fire risk assessor
prioritization could be: (see 3.92).
i) serious breach of legislation, having the potential
for serious injury to occupants; 19.2 The action plan should be such that, if
implemented, it will reduce fire risk to, or maintain
ii) matters that breach legislation but are not
fire risk at, a tolerable level.
considered to constitute a serious threat to life
safety; and
19.3 Where appropriate, the action plan should address
iii) matters that need to be addressed as good both physical fire precautions and managerial issues.
practice, but that do not constitute a significant
threat to occupants. 19.4 The action plan should be both practicable to
implement and possible to maintain, taking into
The implications, in terms of timescales, etc., would account the nature of the premises and the residents.
naturally flow from this.
19.5 The measures recommended in the action plan
Yet another possible scheme could take into should be cost-effective in reducing fire risk. They
account both the cost benefit and the practicality of should be “reasonably practicable”, meaning that the
implementation. For example, minor housekeeping cost, time and trouble involved in implementing any
items could be regarded as suitable for immediate measure are not grossly disproportionate to the risk if
implementation, simply because there is no reason to the measure is not implemented.
delay doing so, regardless of whether there is a major
benefit to the safety of occupants. However, matters 19.6 No new significant hazards to health and safety
that might address a greater threat to residents might should result from implementation of the action plan.
be impossible to implement immediately, in the literal
sense of the term, simply because specifications need to 19.7 The action plan should contain information
be drawn up, tenders obtained, etc. regarding the appropriate effort and urgency
associated with the measures recommended. Effort
In some circumstances, the risk to persons might be and urgency should be proportionate to fire risk, but
so serious that the risk assessor needs to ensure that a financial considerations should also be taken into
suitable representative of the dutyholder is informed account, though only in relation to the fire risk, and
immediately, before the assessor leaves the premises. not in relation to the ability of the dutyholder to pay
A record of the circumstances needs to be recorded for the recommended actions; this avoids a situation in
in the FRA, with, where relevant, a suitable which persons in one premises are placed at greater risk
recommendation to preclude the recurrence of these than persons in another premises, simply because the
circumstances. first dutyholder is less able to afford fire precautions
than the second dutyholder.
Where FRAs are carried out for a large number
of premises of similar type, on behalf of a single 19.8 Where relevant, the action plan should
dutyholder, there can be advantage in an analysis of recommend matters for further investigation by the
all the action plans produced, to give an overview to dutyholder, and areas that need to be checked by the
the dutyholder regarding the state of their portfolio of dutyholder (e.g. where relevant information and access
properties, common problems and prioritization of the to certain areas were not available at the time of
premises in which capital work might be necessary. the FRA).
In this situation, there is a need for procedures to be in
place to ensure the consistency of the FRAs, particularly

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19.9 Where FRAs are carried out for a number of


properties on behalf of a single dutyholder, there
should be arrangements in place to ensure the
consistency of the FRAs in terms of the assessment
of risk and the actions specified in the action plan to
address the risk.
NOTE Such quality assurance procedures are normally
required under third-party certification schemes for
fire risk assessment companies; other than in the case
of sole traders, this involves independent validation
of each FRA by someone other than the person who
carried out the FRA.

19.10 When the FRA is provided to the dutyholder, the


attention of the dutyholder should be drawn to the
presence of the action plan and the need to implement
any recommendations therein.

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20 Periodic review of fire risk assessments

COMMENTARY ON CLAUSE 20 When the FRA is reviewed, consideration needs to


be given to the extent to which the original action
The documented FRA is not intended to be a fire plan has been implemented. Work that has not been
safety manual (see 3.47), albeit that such a manual completed needs to be identified.
is a valuable asset in the management of fire safety,
particularly in large or complex premises. However, the There is no correct or incorrect frequency for the
FRA is a living document, in that it cannot remain valid regular review of the FRA. This is a matter for the
for an unlimited length of time. judgement of the fire risk assessor and, to some extent,
the organization’s own fire safety policy (see 3.49).
The FRA is likely to cease to be valid when, for example: It is, however, appropriate to take account of the likely
a) a material alteration (see 3.63) takes place; frequency of significant changes.
b) a significant change occurs in the “given” factors
A best practice default is commonly annual review
that were taken into account when the FRA was
of FRAs. However, as a general guide, for a low risk,
carried out (see Commentary on Clause 5);
modern, low-rise block of general needs flats (e.g. a
c) a significant change in fire precautions occurs. block of no more than three storeys above ground,
built within the last 20 years), a review every two years
Significant changes in the “given” factors could, for might be sufficient, with a new FRA completed every
example, comprise occupation of supported housing four years. For blocks with higher risk (arising from
by significantly more disabled residents or a change social factors, the age of the building, etc.) and blocks
in the level of staffing of premises in which staff are over four storeys in height, an annual review might be
employed. Significant changes in fire precautions more appropriate, with a new FRA every three years.
include major changes in the provision or design of In extreme cases, for the highest risk premises, an
fire protection measures and major changes in the annual FRA might be appropriate. However, it is not
measures for control or elimination of fire hazards, intended that these suggested frequencies are applied
but also include changes resulting from more gradual prescriptively, as they are not intended to be rigid
deterioration of fire precautions as a result of constant “rules”.
use or lack of maintenance (e.g. wear and tear on fire
doors). Gradual changes can also occur as a result of More frequent reviews might be appropriate where
changes in management, turnover of employees and risk to residents is high as the result of impairments.
minor changes in layout that, after a prolonged period As a general guide, for a low risk, modern, low-rise
and numerous changes, have a significant effect on sheltered housing block (e.g. a block of no more
means of escape. It is also relevant to review the FRA than three storeys above ground, built within the
after any fire. last 20 years), a review every year might be sufficient,
with a new FRA completed every three years.
It follows, therefore, that, when any of the acute step For specialized housing with higher risk (arising from
changes described in items a) to c) above occur, the FRA residents’ disabilities, the age of the building, etc.),
needs to be reviewed. There might also be a need for and premises of over four storeys in height, an annual
approval of such changes under building regulations. review, with a new FRA every two years, might be
Approval of changes by the authority that enforces the more appropriate. For the highest risk premises, an
relevant fire safety legislation is not necessary, unless annual full FRA might be appropriate. Again, these
an “alterations notice” under the legislation requires suggested frequencies are not intended to be applied
that proposed alterations to the premises be notified to prescriptively.
the enforcing authority. However, as gradual changes
over a long period of time can also affect the validity
of the FRA, there is a need for regular review of the
FRA, even if there are no obvious changes that affect its
validity. In FRAs carried out in accordance with this PAS,
judgement of the maximum period after which the FRA
needs to be reviewed on a routine basis is actually part
of the FRA process.

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Review of the FRA is not synonymous with a new b) the period after which major changes in fire
assessment. Equally, however, in a regular review, all precautions are likely to have taken place as a result
aspects of the original FRA might need to be revisited of the measures recommended in the action plan;
to check that they have not been subject to change; and
this emphasizes the importance of adequate recording c) the level of fire risk.
of the significant findings of the original FRA, so that
the basis for its conclusions can be readily re-examined. 20.4 The FRA review should explicitly address the issues
On the other hand, if the review has arisen purely as included in the original FRA, albeit that less detail
the result of a specific material alteration, it might be in the record of the significant findings is necessary,
the case that a limited review is sufficient. particularly in respect of fire precautions that have not
changed since the original FRA.
The original FRA, in conjunction with one or more
documented reviews, constitutes a form of audit trail 20.5 The FRA review should record the name of the
that demonstrates ongoing control of fire safety. After fire risk assessor(s) performing the review, the date(s)
a period of time in which there have, for example, on which the review was carried out and the name(s)
been several reviews in which significant changes and of the principal person(s) with whom there was
the need for new risk control measures have been consultation (e.g. for supply of relevant information) at
identified, the audit trail is likely to become unwieldy. the time of the review. It should also be clear as to the
At that stage, the documentation of a new and number of reviews that have been carried out since the
complete FRA might be appropriate. Typically, not more previous FRA.
than two reviews will be carried out before the next
new and complete FRA. 20.6 The FRA review should record the date by which
the next periodic review is to be carried out.
20.1 The FRA should be subject to review when:
a) material alterations to the premises take place;
b) a significant change occurs in the matters taken into
account when the FRA was carried out;
c) a significant change in fire precautions occurs;
d) there is any other reason to suspect that the original
FRA might no longer be valid (this might include the
occurrence of a fire); and
e) a defined period of time, which is expected to have
been recorded in the original FRA [see 11.1i)], has
elapsed.
NOTE Annex D contains a pro forma that is considered
a suitable and sufficient means for documenting a
review of an existing FRA. The pro forma contained
in Annex D is only a model, in that, if completed by
a competent person (see Clause 7), the scope of the
documented review of the FRA will normally conform
to the recommendations of this PAS. Equally, the
format of a documented FRA may vary from that shown
in Annex D, provided that all recommendations of this
PAS are satisfied.

20.2 When the FRA is reviewed, it should be confirmed


whether any work recommended in the original action
plan has been carried out.

20.3 When determining the frequency of the FRA


review, account should be taken of:
a) the likely frequency of significant alterations to the
premises, or to the nature of the residents;

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21 Type 2, Type 3 and Type 4 fire risk assessments

COMMENTARY ON CLAUSE 21 2) the findings of the inspection carried out for


the purpose of the Type 1 FRA (e.g. evidence of
The following considerations are relevant to this poor compartmentation that warrants further
clause. investigation, or identification of inadequate means
of escape within individual flats);
a) General
3) any requirements of an enforcing authority in
Clause 4 to Clause 20 are (other than as explicitly
relation to the building (e.g. a requirement that,
indicated) concerned solely with a Type 1 FRA
because of the enforcing authority’s concerns
(see 3.95); this is the default FRA necessary for
regarding compartmentation, a Type 2 or Type 4
compliance with the relevant fire safety legislation.
FRA be carried out);
This current clause is concerned with Type 2, Type 3 and
Type 4 FRAs (see 3.96, 3.97 and 3.98 respectively). These 4) concern on the part of the dutyholder regarding an
FRAs are relevant only for buildings in which there are absence of any records of the history of alterations
a number of independent, self-contained units of living and other work carried out in the building [e.g. by a
accommodation, usually with a stay put strategy previous dutyholder(s)];
(see 3.89), such as blocks of flats, sheltered housing and 5) in the case of Type 2 and Type 4 FRAs, the
extra care housing, but not most supported housing. practicality of intrusive inspection work, taking
NOTE 1 The terms “Type 1”, “Type 2”, “Type 3” and into account the acceptability of the resulting
“Type 4” are used in guidance that supports fire safety damage and disruption, as well as the need to avoid
legislation in England and Wales, in which FRAs are disturbance of asbestos;
required for the common parts of blocks of flats. NOTE 2 In the case of buildings constructed
These terms are not used in the equivalent guidance before 2000, before cutting into walls or ceilings,
in Scotland, as the common parts of blocks of flats etc., there is a need to confirm, by reference to
in Scotland (and Northern Ireland) do not require an the asbestos register required by the Control of
FRA under the fire safety legislation in these devolved Asbestos Regulations 2012 [35], that there will be
regions. no undue risk of exposure of occupants, including
the contractor carrying out the work, to asbestos.
When, in the course of a visual inspection as part of NOTE 3 It is commonly the case, in a Type 4 FRA,
a Type 1 FRA, there is a basis for doubt in relation to that opening up of construction in flats is only
the adequacy of structural fire protection (such as practicable in vacant flats.
inadequate compartmentation, poor fire stopping or
6) in the case of a Type 3 FRA, concern on the part of
inadequate fire protection in flats), the action plan of
a dutyholder (such as a landlord or freeholder) that
that FRA might recommend that one of the other types
the fire protection measures within flats might not
of FRA be carried out (or that further investigation be
be adequate to ensure the safety of residents within
carried out by specialists). These other types of FRA
their own flat, even though this is beyond the scope
are normally “one-off” exercises, subsequent to which
of the relevant fire safety legislation;
further FRA reviews follow the principles of a Type 1 FRA.
7) the power of entry to flats; in the case of long
Since a Type 1 FRA is necessary for compliance with leasehold flats, there might be no power under the
the relevant fire safety legislation, the scope of Type 2, lease to carry out Type 3 or Type 4 FRAs, though it
Type 3 and Type 4 FRAs always includes the scope of a is normally feasible and necessary for freeholders to
Type 1 FRA, but involves additional inspection work. arrange entry to a sample of flats for the purpose of
The nature and extent of this additional inspection a Type 1 FRA; and
work depends on many factors, particularly the reason 8) the findings of the inspections (e.g. if, in an initial
for conducting the type of FRA in question. Therefore, sample of intrusive inspections or examination of
relevant factors include: layouts of flats, significant issues are identified,
1) known or suspected deficiencies in further inspection work might be carried out).
compartmentation, or concern regarding the layout
of means of escape within flats;

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It is the responsibility of the dutyholder, not the fire c) Type 3 FRAs (involving non-intrusive inspection of
risk assessor, to determine whether a Type 2, Type 3 or the common parts and a sample of flats)
Type 4 FRA needs to be carried out, in which case this A Type 3 FRA includes the work involved in a Type 1
needs to be made explicit in instructions to the fire risk FRA, but goes beyond the scope of the relevant fire
assessor (e.g. a specification for the FRA). safety legislation (though not the scope of housing
legislation). Type 3 FRAs consider the arrangements for
FRAs of the type now described as Type 1 have been means of escape and fire detection (normally smoke
carried out for blocks of flats under the relevant fire alarms) within at least a sample of the flats. Within
safety legislation since 2006 (and also for workplaces the flats, the inspection is non-destructive, but the fire
generally since 1997). In contrast, the concept of resistance of doors to rooms is considered.
Type 2, Type 3 and Type 4 FRAs was first developed in
2011. Moreover, the vast majority of FRAs for housing Measures to prevent fire are not considered unless
premises comprise Type 1 FRAs. Accordingly, it is (e.g. in the case of maintenance of the electrical and
difficult, at the time of publication of this PAS, to codify heating installations) the measures are within the
any recognized custom and practice in relation to control of, for example, the landlord.
Type 2, Type 3 and Type 4 FRAs.
A Type 3 FRA might sometimes be appropriate for
Every Type 2, Type 3 and Type 4 FRA needs to be rented flats if there is reason to suspect serious risk
“tailor made” for the premises in question, thereby to residents in the event of a fire in their flats.
necessitating agreement between the person for (This might be, for example, because of the age of
whom the FRA is carried out and the fire risk assessor. the block or reason for suspicion of widespread,
The agreement needs to address the exact scope unauthorized material alterations). This type of FRA is
of inspection work over and above that required not possible in long leasehold flats, as there is normally
for a Type 1 FRA, so, in Type 2 and Type 4 FRAs, the no right of access for freeholders.
agreement needs to include the number and locations
of areas in which there is to be opening up of Considerations within flats include matters such as
construction; for Type 3 FRAs, the number of flats to be travel distance, protection of hallways (where relevant),
inspected needs to be specified. ease of opening of the flat entrance door, inner
b) Type 2 FRAs (involving intrusive inspection in the rooms (if any), means of escape from upper levels
common parts) of maisonettes, and provision of smoke alarms (and
heat alarms, if present or necessary). Care needs to be
The scope and objectives of a Type 2 FRA are generally
taken to identify and address bedrooms that are inner
similar to those of a Type 1 FRA, except that there
rooms and that have no suitable escape window, as
is a degree of intrusive inspection, carried out on a
can sometimes be found in old blocks of flats, or where
sampling basis. This usually necessitates the presence
unauthorized alterations have taken place to make a
of a contractor for the purpose of opening up
flat more open plan.
construction and making good after the inspection.
d) Type 4 FRAs (involving intrusive inspection of the
In order to check the integrity of separating common parts and a sample of flats)
construction, the areas in which destructive inspection A Type 4 FRA has the same scope of work as a Type 3
is carried out might sometimes include a sample of FRA, except that there is a degree of intrusive
flats. However, because of the nature of the work, this inspection, in both the common parts and the flats,
can often only be carried out in vacant flats. carried out on a sampling basis. This usually necessitates
the presence of a contractor for the purpose of opening
A Type 2 FRA is usually carried out only if there is up construction and making good after the inspection.
good reason to suspect serious structural deficiencies However, the nature of the work is such that, often,
that could lead to spread of fire beyond the flat of destructive inspection within flats can only be carried
fire origin. The age of the block alone is not generally out in those that are vacant.
sufficient to warrant a Type 2 inspection. The need for
a Type 2 FRA is sometimes identified in a Type 1 FRA, This is the most comprehensive FRA, but is appropriate
but is not simply recommended as a matter of course in only in limited circumstances, such as when a new
all Type 1 FRAs. landlord takes over a block of flats in which the history
of works carried out is unknown and there is reason to
suspect serious risk to residents from both a fire in their
own flats and a fire in neighbours’ flats.

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Within the flats, as well as considering the safety 21.4 The findings of the Type 2, Type 3 or Type 4 FRA
of residents in the event of a fire in their own flat, should be set out in one of the following ways, subject
consideration is given to the potential for fire to to the distinction in the action plan between actions
spread internally from that flat to other flats. Routes required for compliance with the relevant fire safety
to consider are riser shafts running within the flats, legislation and actions recommended beyond those
bathroom and kitchen extract ducts (though these necessary for compliance with the legislation:
might also be regarded as falling within the scope a) a completely separate document from the
of a Type 1 FRA [see item g) of the Commentary documented Type 1 FRA; or
on Clause 15], drainage pipework and other
b) an appendix to the Type 1 FRA; or
penetrations for other services, such as gas and
electricity. c) incorporated in a single composite FRA, setting out
the findings of the various types of FRA in a single
21.1 If a dutyholder requires a Type 2, Type 3 or Type 4 document, subject to clear identification of matters
FRA to be carried out, this should be made explicit and that are not relevant to compliance with the
clear in the instructions to the fire risk assessor. relevant fire safety legislation.
NOTE The findings of a Type 2 and Type 4 FRA (e.g. in
21.2 The scope of the FRA should be appropriate for respect of compartmentation) might be relevant to
the type of FRA in question, and it should be agreed compliance with the relevant fire safety legislation.
between the person who requires the FRA and the fire
risk assessor. In particular, the number and location of
sample areas for intrusive inspection, and the sample
number of flats that are to be inspected, should be
subject to agreement.
NOTE 1 It might be appropriate to extend the number
of samples if the findings of the initial sample suggest
that significant widespread deficiencies exist.
NOTE 2 Typically, in a Type 2 FRA, intrusive inspections
are carried out in a minimum of around four areas.
NOTE 3 In a Type 3 FRA, it is appropriate to inspect at
least one sample of each flat archetype.
NOTE 4 Access to flats for the purpose of a Type 4 FRA
might be restricted to those that are vacant. However,
it is appropriate, if practicable, to carry out intrusive
inspections within at least one sample of each flat
archetype.

21.3 The matters that should be addressed in each type


of FRA should be appropriate to the type of FRA (see
Commentary on this clause).

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22 Person-centred fire risk assessments

COMMENTARY ON CLAUSE 22 Residents of specialized housing range from active


older people to those who require 24 h care. In some
A person-centred FRA (see 3.71) is an assessment of cases, residents of specialized housing can be almost
the risk from fire focused on a specific resident, carried indistinguishable from residents of general needs
out with the involvement of the resident, taking into housing. For these residents, a person-centred approach
account the physical and cognitive characteristics to fire precautions is unnecessary; it will be obvious
of the resident, their lifestyle preferences and a that no additional fire precautions are necessary.
contextualized consideration of relevant behavioural
history. The outcome is a proportionate person-centred At the other extreme, the distinction between a care
action plan that takes into account informed home and a form of specialized housing might largely
decision‑making and dignity of the resident, while be an administrative matter of funding, organizational
resulting in tolerable risk from fire. structure and the source of care provision.

Person-centred FRAs are outside the scope of the While specialized housing, by definition, does not
relevant fire safety legislation and are separate from constitute a residential care home, where residents of
the four types of FRA to which this PAS principally specialized housing have the same levels of need and
relates. As such, this PAS does not give detailed are at the same potential risk from fire as residents of
recommendations for person-centred FRAs. However, a residential care home, it is generally appropriate to
reference to person-centred FRAs is included within this provide measures to ensure a similar level of fire safety,
clause, as they are relevant in the case of specialized based on a person-centred FRA.
housing, and to make clear the distinction between a
person-centred FRA and the four types of FRA to which Detailed guidance on the steps involved in carrying out
this PAS principally relates. Where a vulnerable person a person-centred FRA is given in Part D of Fire safety
in a general needs block of flats comes to the attention in specialised housing [3], published by the National
of a dutyholder, a person-centred FRA can be carried Fire Chiefs Council. Annex E of this PAS contains a
out to identify additional measures to mitigate the risk model pro forma for a person-centred FRA, which is
arising from their vulnerability. reproduced from Fire safety in specialised housing with
the permission of the National Fire Chiefs Council.
The vast majority of fires in specialized housing occur
within residents’ own accommodation. Consequently, 22.1 Where relevant, fire risk assessors should draw the
the vast majority of deaths and serious injuries to attention of dutyholders to the potential need to carry
residents from fires in specialized housing result from out a person-centred FRA for vulnerable residents in
fires that start within a person’s own accommodation specialized housing.
(and often the room in which the fire starts). The fires,
and the deaths or serious injuries that occur from them, 22.2 Where, as the outcome of a person-centred
are not normally the result of inadequate design of the FRA, dutyholders identify undue risk to vulnerable
residents’ private accommodation or deficiencies in fire persons, they should seek the advice of specialists as
safety measures therein. The likelihood of fire and the appropriate.
consequential risk to residents normally arises from the
characteristics of the residents themselves.

The person-centred FRA focuses on the characteristics


of each individual vulnerable resident, in particular the
likelihood that they might start a fire, the potential
for the fire to develop (e.g. as a result of hoarding
behaviour), their capability and mental capacity to
respond to a warning of fire (or sight of a fire) and
their ability to then escape from the fire.

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Annex A (informative)
Model pro forma for documentation
of a fire risk assessment
A.1 This annex contains a model pro forma for A.4 Where description of any fire hazards or fire
documentation of an FRA in England and Wales. precautions is considered appropriate, this can be
(Electronic versions, including modified pro formas for recorded under the appropriate “Relevant information
use in Scotland and Northern Ireland, are available (including description of arrangements and deficiencies
online at https://documentportal.bsigroup.com using observed)” heading in the pro forma. These sections
access code PAS 79:2020.) If the pro forma is properly can also be used to set out justification for acceptance
completed by a competent person, the format and of standards of any fire protection measures that
scope of the FRA will be suitable and sufficient to depart significantly from a prescriptive norm (see 10.4).
satisfy the recommendations of this PAS. Information recorded can include positive findings as
NOTE Enforcement of fire safety legislation is the well as deficiencies, as this helps to contextualize the
prerogative of the enforcing authority charged assessment of risk.
by legislation with the responsibility to do so.
Each enforcing authority is autonomous. There is A.5 While it might not be essential to record further
sometimes debate as to the legal interpretation of information in every section of the pro forma, care
what constitutes the significant findings of an FRA. needs to be taken to ensure that the pro forma
However, the format of the pro forma contained in does not become purely a tick-list with inadequate
this annex, being part of a BSI PAS, is considered by the supporting information. Such an FRA is unlikely to
National Fire Chiefs Council to be one suitable format satisfy fire safety legislation, nor would it meet the
for recording the significant findings of a suitable and recommendations of this PAS.
sufficient FRA, although many other formats would
also be acceptable. A.6 For many types of housing, obtaining relevant
information for completion of the pro forma in this
A.2 The format of a documented FRA may vary annex can prove challenging (e.g. because there is no
from that shown in this annex, provided that the one who can provide the information available on
recommendations of each clause of this PAS are the premises). Under these circumstances, the “No”
satisfied. For example, in the case of means of escape, box should be ticked and an explanation recorded
compliance with Annex C necessitates that the key under “Relevant information (including description of
factors in Table C.1 are explicitly addressed in the arrangements and deficiencies observed)”.
documented FRA, but not all the specific issues shown
in Table C.1 and in the pro forma contained in this A.7 Within the pro forma in this annex, for each main
annex need necessarily be included in all documented topic, the clause within this PAS that provides guidance
FRAs conforming to the recommendations of this PAS, on that topic is shown in parentheses alongside the
as they might not all constitute “significant findings”. topic heading. This is for the guidance of the user of
It is, however, necessary for compliance with this PAS, this PAS, and the clause references need not be shown
that the specific issues have, at least, been considered in the documented fire assessment provided to the
by the fire risk assessor while carrying out the FRA. dutyholder.

A.3 Similarly, the prompt-list of fire hazards shown A.8 For further guidance on the use of the pro forma,
in the pro forma may be expanded. This might be an exemplar of a completed FRA is contained in
appropriate, for example, if there are significant fire Annex G.
hazards for which no headings are included in the
pro forma.

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REGULATORY REFORM (FIRE SAFETY) ORDER 2005


FIRE RISK ASSESSMENT

Responsible person (e.g. employer) or person


having control of the premises:

Address of premises:

Person(s) consulted:

Assessor:

Report validated by:

Date of fire risk assessment:

Date of previous fire risk assessment:

Suggested date for review:

This report is intended to assist you in compliance with Article 9 of the Regulatory Reform (Fire Safety)
Order 2005 (the ‘Fire Safety Order’), which requires that a risk assessment be carried out.

[Date]

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GENERAL INFORMATION

1. THE PREMISES (Clause 12)

1.1 Number of floors at ground level and


above:

Number of floors entirely below ground


level:

Floors on which car parking is provided:

1.2 Number of flats:

1.3 Brief details of construction and approximate age of building:

1.4 Occupancy:

2. THE OCCUPANTS (Clause 12)

2.1 Approximate maximum number of


employees at any one time:

2.2 Approximate maximum number of


residents and visitors at any one time:

3. OCCUPANTS ESPECIALLY AT RISK FROM FIRE (Clause 12)

3.1 Sleeping occupants:

3.2 Occupants in remote areas and lone workers:

3.3 Others:

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PAS 79-2:2020

4. FIRE LOSS EXPERIENCE

5. OTHER RELEVANT INFORMATION

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PAS 79-2:2020

6. RELEVANT FIRE SAFETY LEGISLATION

6.1 The following fire safety legislation applies to these premises:

6.2 The above legislation is enforced by:

6.3 Other legislation that makes significant requirements for fire precautions in these premises
[other than the Building Regulations 2010 (as amended)]:

6.4 The other legislation referred to above is enforced by:

6.5 Is there an alterations notice in force? Yes No

Relevant information and deficiencies observed:

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FIRE HAZARDS AND THEIR ELIMINATION OR CONTROL

7. ELECTRICAL SOURCES OF IGNITION (Clause 13 and Annex B)

7.1 Are reasonable measures taken to prevent fires of electrical Yes No


origin?

7.2 More specifically:

a) Are fixed installations periodically inspected and tested? N/A Yes No

b) Is portable appliance testing carried out? N/A Yes No

Relevant information (including description of arrangements and deficiencies observed):

8. SMOKING (Clause 13 and Annex B)

8.1 Are reasonable measures taken to prevent fires as a result of Yes No


smoking?

8.2 More specifically:

a) Is smoking prohibited in appropriate areas? N/A Yes No

b) Are there suitable arrangements for those who wish to N/A Yes No
smoke?

c) Did the smoking policy appear to be observed at time of N/A Yes No


inspection?

d) Are “No smoking” signs provided in the common areas? Yes No

Relevant information (including description of arrangements and deficiencies observed):

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9. ARSON (Clause 13 and Annex B)

9.1 Does basic security against arson by outsiders appear Yes No


reasonable1)?

9.2 Is there an absence of unnecessary fire load in close proximity Yes No


to the premises or available for ignition by outsiders?

Relevant information (including description of arrangements and deficiencies observed):

1) Reasonable only in the context of this fire risk assessment. If specific advice on security (including security against arson) is required,
this should be obtained from a security specialist.

10. PORTABLE HEATERS AND HEATING AND VENTILATION INSTALLATIONS


(Clause 13 and Annex B)

10.1 Is there satisfactory control over the use of portable heaters? N/A Yes No

10.2 Are fixed heating and ventilation installations subject to N/A Yes No
regular maintenance?

Relevant information (including description of arrangements and deficiencies observed):

11. COOKING (Clause 13 and Annex B)

11.1 Are reasonable measures taken to prevent fires as a result of N/A Yes No
cooking?

Relevant information (including description of arrangements and deficiencies observed):

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PAS 79-2:2020

12. LIGHTNING (Clause 13 and Annex B)

12.1 Does the building have a lightning protection system? Yes No

Relevant information and deficiencies observed:

13. HOUSEKEEPING (Clause 13 and Annex B)

13.1 Is the overall standard of housekeeping adequate? Yes No

13.2 More specifically:

a) Do combustible materials appear to be separated from Yes No


ignition sources?

b) Is unnecessary accumulation or inappropriate storage of Yes No


combustible materials or waste avoided?

c) Are gas and electricity intake/meter cupboards N/A Yes No


adequately secured and kept clear of combustible
materials?

Relevant information (including description of arrangements and deficiencies observed):

14. HAZARDS INTRODUCED BY OUTSIDE CONTRACTORS AND BUILDING WORKS


(Clause 13 and Annex B)

14.1 Is there satisfactory control over works carried out in the N/A Yes No
building by contractors?

Relevant information (including description of arrangements and deficiencies observed):

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15. DANGEROUS SUBSTANCES2) (Clause 13)

15.1 Are the general fire precautions adequate to address the N/A Yes No
hazards associated with dangerous substances used or stored
within the premises3)?

Relevant information and deficiencies observed:

2) For the purpose of this risk assessment and the Fire Safety Order, dangerous substances are primarily explosive, highly flammable or
flammable substances and oxidizing agents.
3) Small quantities with negligible impact on the appropriate fire precautions need not be taken into account.

16. OTHER SIGNIFICANT FIRE HAZARDS THAT WARRANT CONSIDERATION

16.1 Hazards:

Relevant information and deficiencies observed:

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FIRE PROTECTION MEASURES

17. MEANS OF ESCAPE [Clause 15c) and Annex C]

17.1 Is the design and maintenance of the means of escape Yes No


considered adequate?

17.2 More specifically


a) Are there reasonable distances of travel:

- where there is escape in a single direction? N/A Yes No

- where there are alternative means of escape? N/A Yes No

b) Is there adequate provision of exits? N/A Yes No

c) Do fire exits open in the direction of escape, where N/A Yes No


necessary?

d) Are the arrangements provided for securing exits N/A Yes No


satisfactory?

e) Is the fire-resisting construction (including any glazing) N/A Yes No


protecting escape routes and staircases of a suitable
standard and maintained in sound condition?

f) Is the fire resistance of doors to staircases and the common N/A Yes No
areas considered adequate, and are the doors maintained
in sound condition?

g) Are suitable self-closing devices fitted to doors in the N/A Yes No


common areas?

h) Is the fire resistance of doors to meter cupboards/store N/A Yes No


rooms/plant rooms in the common areas considered
adequate, and are they adequately secured and/or fitted
with suitable self-closing devices?

i) Is the fire resistance of flat entrance doors considered N/A Yes No


adequate, and are doors maintained in sound condition?

j) Are suitable self-closing devices fitted to flat entrance N/A Yes No


doors and, where fitted, maintained in good working
order?

k) Are there adequate smoke control provisions to protect N/A Yes No


the common escape routes, where necessary?

l) Are all escape routes clear of obstructions? N/A Yes No

m) Are all fire exits easily and immediately openable? N/A Yes No

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n) Is it considered that the premises are provided with N/A Yes No


reasonable arrangements for means of escape for disabled
people?

Relevant information (including description of arrangements and deficiencies observed):

18. MEASURES TO LIMIT FIRE SPREAD AND DEVELOPMENT [Clause 15g)]

18.1 Is it considered that there is/are:

a) adequate levels of compartmentation between floors and Yes No


between flats and the common escape routes?

b) reasonable limitation of linings to escape routes that Yes No


might promote fire spread?

c) as far as can reasonably be ascertained, reasonable fire N/A Yes No


separation within any roof space?

d) adequately fire protected service risers and/or ducts in N/A Yes No


common areas, that will restrict the spread of fire and
smoke?

18.2 As far as can reasonably be ascertained, are fire dampers N/A Yes No
provided as necessary to protect critical means of escape
against passage of fire, smoke and products of combustion
in the early stages of a fire4), 5)?

Relevant information (including description of arrangements and deficiencies observed):

4) This fire risk assessment will not necessarily identify all minor fire stopping issues that might exist within the building. If you become
aware of other fire stopping issues, or are concerned about the adequacy of fire stopping, you may wish to consider arranging for
an invasive survey by a competent specialist.
5) A full investigation of the design of heating, ventilation and air conditioning systems is outside the scope of this fire risk assessment.

19. EMERGENCY ESCAPE LIGHTING [Clause 15e)]

19.1 Has a reasonable standard of emergency escape lighting been N/A Yes No
provided6)?

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Relevant information (including description of arrangements and deficiencies observed):

6) Based on visual inspection, but no test of illuminance levels or verification of full compliance with relevant British Standards carried
out.

20. FIRE SAFETY SIGNS AND NOTICES [Clause 15d)]

20.1 Is there a reasonable standard of fire safety signs and notices? N/A Yes No

Relevant information (including description of arrangements and deficiencies observed):

21. MEANS OF GIVING WARNING IN CASE OF FIRE [Clause 15b)]

21.1 Is a reasonable fire detection and fire alarm system provided N/A Yes No
in the common areas, where necessary7)?

21.2 If there is a communal fire detection and fire alarm system, N/A Yes No
does it extend into the dwellings?

21.3 Where appropriate, has a fire alarm zone plan been N/A Yes No
provided?

21.4 Where appropriate, are there adequate arrangements for N/A Yes No
silencing and resetting an alarm condition?

Relevant information (including description of arrangements and deficiencies observed):

Relevant information on false alarm experience (if known):

7) Based on visual inspection, but no audibility tests or verification of full compliance with relevant British Standard carried out.

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22. MANUAL FIRE EXTINGUISHING APPLIANCES [Clause 15f)]

22.1 Is there reasonable provision of manual fire extinguishing N/A Yes No


appliances?

22.2 Are all fire extinguishing appliances readily accessible? N/A Yes No

Relevant information (including description of arrangements and deficiencies observed):

23. RELEVANT AUTOMATIC FIRE EXTINGUISHING SYSTEMS8) [Clause 15h)]

23.1 Type of fixed system:

Relevant information and deficiencies observed:

8) Relevant to life safety and this risk assessment (as opposed to property protection).

24. OTHER RELEVANT FIXED SYSTEMS AND EQUIPMENT9) [Clause 15i)]

24.1 Type of fixed system:

Relevant information and deficiencies observed:

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24.2 Are there appropriately sited facilities for electrical isolation of N/A Yes No
any photovoltaic (PV) cells, with appropriate signage, to assist
the fire and rescue service?

Relevant information (including description of arrangements and deficiencies observed):

9) Relevant to life safety and this risk assessment (as opposed to property protection).

MANAGEMENT OF FIRE SAFETY

25. PROCEDURES AND ARRANGEMENTS (Clause 16)

25.1 Safety assistance:

The competent person(s) appointed under Article 18 of the Fire Safety Order to assist the
responsible person in undertaking the preventive and protective measures (i.e. relevant general fire
precautions) is:

25.2 Fire safety at the premises is managed by10):

25.3 Is there a suitable record of the fire safety arrangements? Yes No

Relevant information (including description of arrangements and deficiencies observed):

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25.4 Evacuation strategy

Stay put
Simultaneous evacuation
Other (please specify below)

Comment:

25.5 Are procedures in the event of fire appropriate and properly Yes No
documented, where appropriate11)?

Relevant information (including description of arrangements and deficiencies observed):

25.6 Are routine in-house inspections of fire precautions undertaken N/A Yes No
(e.g. in the course of health and safety inspections)?

Relevant information (including description of arrangements and deficiencies observed):

10) This is not intended to represent a legal interpretation of responsibility, but merely reflects the managerial arrangement in place at
the time of this risk assessment.
11) Based on brief review of procedures at the time of this fire risk assessment. In-depth review of documentation is outside the scope
of this fire risk assessment, unless otherwise stated.

26. TRAINING AND DRILLS [Clause 16h)]

26.1 Are all staff given adequate fire safety instruction and training? N/A Yes No

Relevant information (including description of arrangements and deficiencies observed):

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26.2 When the employees of another employer work in the N/A Yes No
premises, is appropriate information on fire risks and fire safety
measures provided?

Relevant information (including description of arrangements and deficiencies observed):

27. TESTING AND MAINTENANCE [Clause 16j)]

27.1 Is there adequate maintenance of the premises? Yes No

Relevant information (including description of arrangements and deficiencies observed):

27.2 Is weekly testing and periodic servicing of the fire detection N/A Yes No
and fire alarm system undertaken?

Relevant information (including description of arrangements and deficiencies observed):

27.3 Are monthly and annual testing routines in place for the N/A Yes No
emergency escape lighting?

Relevant information (including description of arrangements and deficiencies observed):

27.4 Is annual maintenance of fire extinguishing appliances N/A Yes No


undertaken?

Relevant information (including description of arrangements and deficiencies observed):

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27.5 Are six-monthly inspection and annual testing of rising mains N/A Yes No
undertaken?

Relevant information (including description of arrangements and deficiencies observed):

27.6 Are weekly and monthly testing, six-monthly inspection, and N/A Yes No
annual inspection and testing undertaken of lift(s) provided for
use by firefighters or evacuation of disabled people (evacuation
lifts)?

Relevant information (including description of arrangements and deficiencies observed):

27.7 Other relevant inspections or tests:

Relevant information (including description of arrangements and deficiencies observed):

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28. RECORDS [Clause 16k)]

28.1 Are there appropriate records of:

a) Fire alarm tests (where relevant)? N/A Yes No

b) Emergency escape lighting tests? N/A Yes No

c) Maintenance and testing of other fire protection systems N/A Yes No


and equipment?

Relevant information (including description of arrangements and deficiencies observed):

29. PREMISES INFORMATION BOX [Clause 15c)]

29.1 Is there a suitably located premises information box for the fire N/A Yes No
and rescue service? 12)

29.2 Are there arrangements to keep the premises information box N/A Yes No
up to date? 12)

Relevant information (including description of arrangements and deficiencies observed):

12) Normally applicable only to sheltered and extra care housing.

30. ENGAGEMENT WITH RESIDENTS [Clause 16l)]

30.1 Has information on fire procedures been disseminated to N/A Yes No


residents?

30.2 Is fire safety information disseminated to residents? N/A Yes No

Relevant information (including description of arrangements and deficiencies observed):

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FIRE RISK ASSESSMENT

The following simple risk level estimator is based on a commonly used risk level estimator:

Potential consequences
of fire è
Slight harm Moderate harm Extreme harm
Likelihood of fire ê

Low Trivial risk Tolerable risk Moderate risk

Medium Tolerable risk Moderate risk Substantial risk

High Moderate risk Substantial risk Intolerable risk

Taking into account the fire prevention measures observed at the time of this risk assessment, it is
considered that the hazard from fire (likelihood of fire) at these premises is:

Low Medium High

In this context, a definition of the above terms is as follows:

Low: Unusually low likelihood of fire as a result of negligible potential sources of


ignition.

Medium: Normal fire hazards (e.g. potential ignition sources) for this type of occupancy,
with fire hazards generally subject to appropriate controls (other than minor
shortcomings).

High: Lack of adequate controls applied to one or more significant fire hazards, such
as to result in significant increase in likelihood of fire.

Taking into account the nature of the premises and the occupants, as well as the fire protection and
procedural arrangements observed at the time of this fire risk assessment, it is considered that the
consequences for life safety in the event of fire would be:

Slight harm Moderate harm Extreme harm

In this context, a definition of the above terms is as follows:

Slight harm: Outbreak of fire unlikely to result in serious injury or death of any occupant.

Moderate harm: Outbreak of fire could foreseeably result in injury (including serious injury) of
one or more occupants, but is unlikely to result in multiple fatalities.

Extreme harm: Significant potential for serious injury or death of one or more occupants.

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Accordingly, it is considered that the risk to life from fire at these premises is:

Trivial Tolerable Moderate Substantial Intolerable

Comments:

A suitable risk-based control plan should involve effort and urgency that are proportional to risk.
The following risk-based control plan is based on one advocated for general health and safety risks:

Risk level Action and timescale

Trivial No action is required, and no detailed records need be kept.

No major additional controls required. However, there might be a need for


Tolerable
improvements that involve minor or limited cost.

It is essential that efforts are made to reduce the risk. Risk reduction measures
should be implemented within a defined time period.

Moderate Where moderate risk is associated with consequences that constitute extreme
harm, further assessment might be required to establish more precisely the
likelihood of harm as a basis for determining the priority for improved control
measures.

Considerable resources might have to be allocated to reduce the risk. If the


Substantial building is unoccupied, it should not be occupied until the risk has been reduced.
If the building is occupied, urgent action should be taken.

Intolerable Building (or relevant area) should not be occupied until the risk is reduced.

NOTE THAT, ALTHOUGH THE PURPOSE OF THIS SECTION IS TO PLACE THE FIRE RISK IN CONTEXT,
THE ABOVE APPROACH TO RISK ASSESSMENT IS SUBJECTIVE AND FOR GUIDANCE ONLY. ALL
HAZARDS AND DEFICIENCIES IDENTIFIED IN THIS REPORT SHOULD BE ADDRESSED BY
IMPLEMENTING ALL RECOMMENDATIONS CONTAINED IN THE FOLLOWING ACTION PLAN. THE FIRE
RISK ASSESSMENT SHOULD BE REPEATED REGULARLY.

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ACTION PLAN

It is considered that the following actions should be implemented in order to reduce fire risk to, or
maintain it at, the following level:

Trivial Tolerable

Definition of priorities (where applicable):

Item Recommendation Priority Timescale

1.

2.

Interim measures (where appropriate)

3.

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REFERENCES
[It is normal practice for the FRA to include a list of relevant references.]

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Annex B (informative)
Fire hazard prompt-list

B.1 The following fire hazards are normally considered B.2 Comprehensive guidance on the typical fire hazards
in the FRA: found in housing premises, and means for their control
a) electrical faults, the fire hazard of which needs to or elimination, is given in the following publications,
be addressed by periodic inspection and testing which contain comprehensive bibliographies relating
of fixed electrical installations, portable appliance to specific fire hazards:
testing (e.g. of any portable electrical equipment • Fire safety in purpose-built blocks of flats, published
supplied to tenants or in offices); by the Local Government Association [1];
b) smoking, which, other than within residents’ own • Practical fire safety guidance for existing high
dwellings, is controlled under legislation, assisted rise domestic buildings, published by Scottish
by suitable signage; Government [2];
c) malicious ignition, the hazard of which can be • Fire safety in specialised housing – Guidance,
addressed by suitable security of the building published by the National Fire Chiefs Council [3];
to prevent malicious ignition by outsiders • Practical fire safety for existing specialised housing
(e.g. electronic access control in blocks of flats) and similar premises, published by Scottish
and avoidance of unnecessary fire load in close Government [4];
proximity to the building;
• Mobility scooter guidance for residential buildings,
d) improper use of portable heaters, which, other than published by NFCC [36].
in residents’ own dwellings, ought to be avoided
as far as possible, and ought to be limited to
appliances that are the least hazardous;
e) faults in fixed heating installations, which ought to
be subject to regular maintenance;
f) use of cooking appliances (e.g. in communal
lounges and kitchens in sheltered housing), giving
rise to the need for the availability of suitable fire
extinguishing appliances, cleaning of any filters and
ductwork in ventilation extract facilities that might
be found in larger kitchens, etc;
g) lightning, the hazard of which is addressed by
lightning protection in taller buildings;
NOTE Compared with the other fire hazards
described above, lightning is not a significant cause
of fire. For example, in 2019–2020, lightning is
known to have caused only nine fires in dwellings
(0.03% of all fires in dwellings in England). None
of these fires occurred in blocks of flats, and none
resulted in a fatality.

h) contractors’ operations, in respect of which there


is a need for suitable contract conditions and site
control, particularly in relation to “hot work”,
involving cutting, welding, use of blowlamps, etc;
and
i) poor housekeeping, necessitating control over
combustible materials in common parts and suitable
policies in relation to storage of mobility scooters
and electric vehicles.

© The British Standards Institution 2020 91


PAS 79-2:2020

Annex C (normative)
Key factors to consider in assessment
of means of escape

C.1 The key factors shown in Table C.1  should always


be explicitly considered in assessment of means of
escape. Most of the factors are quite broad and
encompass a number of more specific issues. These key
factors can be used as a form of prompt-list and should,
therefore, normally be shown in the documented
FRA (see Clause 10), as proof that they have been
considered.

C.2 The more specific issues should always be


considered in the FRA process, but might or might not
be explicitly shown in the documented FRA.
NOTE Where the experience of the fire risk assessor is
limited, it might be of value for at least some of the
specific issues to be included in the pro forma used, so
that they act as prompts or reminders to the fire risk
assessor.

C.3 Where it is determined that there are significant


departures in compliance of any key factor or specific
issue with recognized guidance or codes of practice,
but it is considered that the departures are acceptable
(and, hence, no relevant recommendation needs to
be made in the action plan), the reasoning behind the
acceptance of each departure should be documented
in the FRA (see 10.4).
NOTE Guidance on means of escape is contained in
government guidance documents that support the
relevant fire safety legislation.

92 © The British Standards Institution 2020


Table C.1 – Key factors and specific issues to consider in means of escape

Key factor Specific issues to consider Notes


Design of escape routes • Do escape routes lead to final exits? —
• Do doors on means of escape open in the direction
of escape where necessary?
• Are doors on means of escape fitted with
appropriate panic bolts or latches?
• Will occupants of inner rooms (see 3.57) be aware

© The British Standards Institution 2020


of a fire in the access rooms?
• Do revolving doors or sliding doors have suitable
bypass doors where necessary?
• Are there (and is there a need for) alternative
escape routes (see 3.4)?
Distances of travel • Are travel distances (see 3.94) reasonable? Recommended maximum travel distances are given
• Are travel distances in dead ends (see 3.16) suitably in all guidance documents and codes of practice
limited? on means of escape, but these figures should not
be considered in isolation of other fire protection
measures (see Commentary on Clause 15). The likely
rate of fire development, and the consequent time
available for escape, need to be taken into account.
Protection of escape routes • Are escape routes, such as staircases, dead end Where automatic door release mechanisms are used,
corridors, bedroom corridors, etc., protected it is important to ensure that there is adequate
(see 3.77) where necessary? provision of suitably sited smoke detectors and
• Are all fire doors properly selfclosing, kept locked that the interface with the fire alarm system
shut or only held open by suitable, correctly is appropriate. Recommendations are given in
functioning automatic door release mechanisms BS 7273‑4.
(see 3.5)?
Adequate provision of exits and escape • Is there a sufficient number of fire exits and escape Methods of calculating exit capacity are given in all
routes routes? codes of practice that cover means of escape.
• Are the number and widths of fire exits and escape
routes sufficient for the number of occupants?

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Table C.1 – Fire hazards, elimination or control measures and relevant codes of practice (continued)

94
Fire hazard Typical key measures for control or elimination of Relevant code of practice or guidance document
the fire hazard
Exits easily and immediately openable • Are fire exits easily openable without, for example,
the use of a key?
PAS 79-2:2020

• Is there only a single means of securing each fire


exit?
• Where necessary, do the means of securing fire
exits comprise panic bolts (see 3.68) or panic latches
(see 3.69)?
• Where electronic locking is used, is its use Recommendations on the interface between fire
acceptable, and are the means of releasing the detection and fire alarm systems and electronically
locks suitable? secured doors are given in BS 7273-4.
Escape routes unobstructed • Are escape routes kept unobstructed? Escape route widths should be sufficient for the
• Are adequate widths of corridors and other escape number of people who need to use the escape route.
routes maintained at all times?

© The British Standards Institution 2020


PAS 79-2:2020

Annex D (informative)
Model pro forma for documentation of a
review of an existing fire risk assessment

D.1 This annex contains a pro forma for documentation


of a review of an existing FRA in England and Wales.
(Electronic versions, including modified pro formas for
use in Scotland and Northern Ireland, are available
online at https://documentportal.bsigroup.com using
access code PAS 79:2020.) If the pro forma is properly
completed by a competent person, the format and
scope of the review will be suitable and sufficient to
satisfy the recommendations in Clause 20.

D.2 The format of the documented review may


vary from that shown in this annex, provided the
recommendations in Clause 20 are satisfied.
For example, the level to which principal issues are
broken down into their component factors may vary,
provided it is clear that the principal issues addressed
in the original FRA have been addressed, or that
the scope of the review is limited to, for example, a
material alteration that has resulted in the review
(see Clause 20).
NOTE A review of an FRA does not necessarily involve
completion of a pro forma, but this annex offers a
record of the review that may be made.

© The British Standards Institution 2020 95


PAS 79-2:2020

REGULATORY REFORM (FIRE SAFETY) ORDER 2005


PERIODIC REVIEW OF FIRE RISK ASSESSMENT

Responsible person (e.g. employer) or person


having control of the premises:

Address of premises:

Person(s) consulted:

Assessor:

Date of this fire risk assessment review:

Date of full fire risk assessment that is under


review:

Date(s) of full fire risk assessment review(s):

Review number (e.g. 1 or 2):

Suggested date for next review1):


OR

Suggested date for next full fire risk


assessment:

The purpose of this report is to provide an assessment of the risk to life from fire in these
premises and, where appropriate, to make recommendations to ensure compliance with fire
safety legislation. The report does not address the risk to property or business continuity from
fire.

[Date]

1) The original fire risk assessment should be reviewed again, or a full fire risk assessment undertaken, by a competent
person by the date indicated above or at such earlier time as there is reason to suspect that it is no longer valid or if
there has been a significant change in the matters to which it relates, or if a fire occurs.

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GENERAL INFORMATION

1. Significant changes identified since the time of the previous fire risk assessment in respect
of:
1.1 The premises:

1.2 The occupancy:

1.3 The occupants (including occupants especially at risk from fire):

1.4 Fire loss experience:

1.5 Application of fire safety legislation:

1.6 Other relevant information:

FIRE HAZARDS AND THEIR ELIMINATION OR CONTROL

2. Significant changes in measures to prevent fire since the time of the fire risk assessment:

PAS 79-2 Draft 4.3 22 [no copyright on pro forma]

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3.1 Are there adequate measures to prevent fire? Yes No

3.2 Comments and hazards observed:

4.1 Are housekeeping and maintenance adequate? Yes No

4.2 Comments and deficiencies observed:

FIRE PROTECTION MEASURES

5.1 Significant changes in fire protection measures since the time of the fire risk assessment:

6.1 Are the means of escape from fire adequate? Yes No

6.2 Comments and deficiencies observed:

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7.1 Are compartmentation and linings satisfactory?2) Yes No

7.2 Comments and deficiencies observed:

8.1 Is there reasonable emergency escape lighting?3) Yes No

8.2 Comments and deficiencies observed:

9.1 Are there adequate fire safety signs and notices? Yes No

9.2 Comments and deficiencies observed:

2) Based on a sample inspection of readily accessible areas.


3) Based on visual inspection only.

PAS 79-2 Draft 4.3 24 [no copyright on pro forma]

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10.1 Are the means of giving warning of fire adequate?4) Yes No

10.2 Comments and deficiencies observed:

11.1 Is the provision of fire extinguishing appliances adequate? Yes No

11.2 Comments and deficiencies observed:

12.1 Comments on other fixed fire protection systems:

4) Based on visual inspection only.

PAS 79-2 Draft 4.3 25 [no copyright on pro forma]

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MANAGEMENT OF FIRE SAFETY

13.1 Significant changes in management of fire safety since the time of the fire risk assessment:

14.1 Are arrangements for management of fire safety adequate? Yes No

14.2 Comments and deficiencies observed:

15.1 Are fire procedures adequate? Yes No

15.2 Comments and deficiencies observed:

PAS 79-2 Draft 4.3 26 [no copyright on pro forma]

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16.1 Are the arrangements for staff training and fire drills Yes No
adequate?

16.2 Comments and deficiencies observed:

17.1 Are the arrangements for testing and maintenance of Yes No


fire protection systems and equipment adequate?

17.2 Comments and deficiencies observed:

18.1 Are there adequate records of testing, maintenance, Yes No


training and drills?

18.2 Comments and deficiencies observed:

19 Are there continuing arrangements for the premises N/A Yes No


information box to be kept up to date?

20.1 Are there continuing arrangements for engagement N/A Yes No


with residents?

20.2 Comments and deficiencies observed:

PAS 79-2 Draft 4.3 27 [no copyright on pro forma]

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FIRE RISK ASSESSMENT

On the basis of the criteria set out in the original fire risk assessment, it is considered that the
current risk to life from fire at these premises is:

Trivial Tolerable Moderate Substantial Intolerable

PAS 79-2 Draft 4.3 28 [no copyright on pro forma]


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ACTION ON PREVIOUS ACTION PLAN

Have all previous recommendations been satisfactorily addressed?

Yes No

Brief details of recommendations not yet implemented.

1.

PAS 79-2 Draft 4.3 29 [no copyright on pro forma]

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NEW ACTION PLAN

It is considered that the following recommendations should be implemented, along with any
outstanding actions in the original fire risk assessment/previous review, in order to reduce fire risk to,
or maintain it at, the following level:

Trivial Tolerable

Definition of priorities (where applicable):

Item Recommendation Priority Timescale

1.

PAS 79-2 Draft 4.3 30 © The British Standards Institution 2020


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Annex E (informative)
Model pro forma for a person-centred
fire risk assessment

E.1 This annex contains a model pro forma on which a


person-centred FRA can be recorded. The pro forma is
reproduced from Fire safety in specialised housing [3],
with the permission of the National Fire Chiefs Council.

E.2 A person-centred FRA is quite separate from the


FRA required under the relevant fire safety legislation.
Its purpose is to address the risk of vulnerable residents
in specialized housing from fire. In sheltered and
extra care housing, a person-centred FRA is often
only appropriate for high-risk residents. In supported
housing, where the number of residents in any property
is usually small, a person-centred FRA can easily be
carried out for every resident.

E.3 The pro forma leads the user to consider the


propensity of the resident to contribute to the
likelihood of fire or fire development, the mental
capacity of the resident to recognize and respond
appropriately to fire alarm signals or signs of fire, and
the ability of the resident to escape in the event of
fire. The outcome of the person-centred FRA comprises
a person‑centred approach to fire safety for the most
vulnerable residents, which can comprise measures to
prevent fire, measures to protect residents if fire occurs
and enhanced engagement with residents, often with
input from the fire and rescue service.

E.4 Guidance on carrying out a person-centred FRA and


use of the pro forma in this annex is given in Part D of
Fire safety in specialised housing [3].

106 © The British Standards Institution 2020


PAS 79-2:2020

Record of person-centred fire risk assessment


Full Address Resident Name

Date Name of Assessor

Date for review

Outstanding Additional
Hazard and Circumstances Further details of current Details of any existing control
risk actions
risk factors (circle as appropriate) circumstances measures
(Yes or No) required
Non-smoker

No further consideration required.


Smokes but no signs of
careless handling

Smokes and signs of � Does not use reduced ignition


careless handling propensity cigarettes.

Smoking � Discarded cigarettes and matches.


� A few burn marks found on carpets.
� Multiple burn marks found on carpet.
� Cigarette burns to clothes or
furnishings.
� Other (please specify):

Outstanding Additional
Hazard and Circumstances Further details of current Details of any existing control
No cooking facilities. risk actions
risk factors (circle as appropriate) circumstances measures
(Yes or No) required
No further consideration required.
Cooking, but no evidence or
suggestion of careless
behaviour. 201 Fire safety in specialised housing
Cooking and evidence or � Inappropriate use of cooking
suggestion of careless equipment (e.g. microwave ovens).
Cooking behaviour.
� May occasionally leave cooking
unattended.
� Likely to leave cooking unattended.
� History of alarm signals or small fires
from cooking.
� Other (please specify):

Equipment safely used and


maintained.

Extensive use of extension No further consideration required.


leads and adapters and/or
electric blankets, but
adequately maintained.
Use of extension leads and � Cube adapters.
Electrical adapters and/or electric
blankets, but lack of � Potential overloading of circuits.
maintenance or signs of � Worn equipment or cables.
wear and tear.
� Electric blankets not maintained
regularly.
� Other (please specify):

Fire safety in specialised housing 202

270

© National Fire Chiefs Council 107


PAS 79-2:2020

Outstanding Additional
Hazard and Circumstances Further details of current Details of any existing control
risk actions
risk factors (circle as appropriate) circumstances measures
(Yes or No) required
No use of portable heaters.

Portable heaters limited to No further consideration required.


oil-filled radiators or
convector heaters compliant
with modern standards.

Portable
Higher hazard portable � Evidence of heaters sited too close to
heaters, such as fan heaters, combustible materials.
heaters
radiant bar fires or paraffin
heaters. � Likelihood of heaters sited too close
to combustible materials.
� Potential for other careless use (e.g.
drying clothes, warming meals, etc.).
� Other (please specify):

No candle use.

No further consideration required.


Use of Candles used, but with
candles appropriate precautions

Candle use without � Please specify:


appropriate precautions.

No history of, or likely


potential for, deliberate No further consideration required.
ignition.
No history of deliberate Please specify: Outstanding Additional
Hazard and Circumstances Further details of current Details of any existing control
ignition, butassome potential. risk actions
risk factors (circle appropriate) circumstances measures
Deliberate (Yes or No) required
ignition History or likelihood of � Previous history of deliberate ignition.
deliberate ignition.
� History of malicious false alarms to
the fire and rescue service.
203 Fire safety in specialised housing
� Other (please specify):

None.
Fire Safety in Specialised Housing
No further consideration required.
Alcohol or drug use, with no
other high fire risk behaviour.

Alcohol or Significant alcohol or drug � Evidence or likelihood of careless


drug use use, combined with high fire handling of smoking materials.
risk behaviour.
� Evidence or likelihood of leaving
cooking unattended.
� Other (please specify):

No hoarding, or hoarding of
Outstanding Additional
Hazard and generally Circumstances
non-combustible Further details of current Details of any existing control Outstanding Additional
Hazard and
risk factors Circumstances
(circle
materials as appropriate)
that do not obstruct Further details of current
circumstances
No further consideration
Details of any required.
existing
measures control risk actions
risk factors (circle
escape as appropriate)
routes. circumstances measures (Yesrisk
or No) actions
required
(Yes or No) required
Hoarding between clutter � Hoarding confined to a single room.
Hoarding
levels 1 andbetween
413 clutter Hoarding confined to a single room.
levels 1 and 47) � Hoarding in more than one room.
Hoarding in more than one room.
� Hoarding within escape route.
Hoarding within escape route.
Types of materials hoarded: Outstanding Additional
Hoarding
Hazard and Circumstances Further
Types details hoarded:
of materials of current Details of any existing control
risk actions
(access)
risk factors (circle as appropriate) circumstances measures
(Yes or No) required
Hoarding between clutter � Hoarding confined to a single room.
Hoarding
levels 1 between
5 and 4 7)
913 clutter � Hoarding confined to a single room.
levels 5 and 914 � Hoarding in more than one room.
� Hoarding in more than one room.
� Hoarding within escape route.
271
Fire safety in specialised housing � Hoarding within escape route.
204
Types of materials hoarded:
Types of materials hoarded:

No oxygenbetween
Hoarding used. clutter � Hoarding confined to a single room.
No oxygen
levels 5 andused.
914 No further consideration required.
� Hoarding in more than one room. No further consideration required.
Oxygen Use of oxygen combined �
� Oxygen
Hoardinguse combined
within escapewith smoking.
route.
Oxygen Use of oxygen
with high combined
fire risk behaviour. � Oxygen use combined with smoking.
7)
Visual images ofhigh
with clutter ratings
fire risk are set� out
behaviour. in Appendix
Other
Types (please 4hoarded:
of Fire safety in specialised housing [3].
specify):
of materials
� Other (please specify):

None.
No oxygen used.
None. No further consideration required.

Sensory Outstanding Additional


Hard
Use ofofoxygen
hearing, or partially
combined � Please specify:
of Circumstances
Oxygen
Hazard and
Sensory
impairment Oxygen usedetails
Further combined with smoking.
of current Details of any existing control
Hard
sighted. hearing, or partially Please specify: risk actions
with (circle
high fire risk behaviour.
108
impairment
risk factors sighted. as appropriate) � circumstances
Other (please specify): measures
©(Yes
National
or No)Fire Chiefs Council
required
Deaf or blind. Please specify:

None. No further consideration required.


� Hoarding in more than one room.
� Hoarding within escape route.
Types of materials hoarded: Outstanding Additional
Hazard and Circumstances Further details of current Details of any existing control
risk factors (circle as appropriate) circumstances measures PAS 79-2:2020
risk
(Yes or No)
actions
required
Hoarding between clutter � Hoarding confined to a single room.
levels 1
5 and 4 7)
913
� Hoarding in more than one room.
� Hoarding within escape route.
Types of materials Outstanding Additional
Hazard and Circumstances Further details hoarded:
of current Details of any existing control
risk actions
risk factors (circle as appropriate) circumstances measures
(Yes or No) required
Hoarding
No oxygenbetween
used. clutter � Hoarding confined to a single room.
levels 1 7)
13
914
5 and 4 No further consideration required.
� Hoarding in more than one room.
Oxygen Use of oxygen combined �
� Oxygen
Hoardinguse combined
within escapewith smoking.
route.
with high fire risk behaviour.
� Other
Types (please specify):
of materials hoarded:

None.
No oxygenbetween
Hoarding used. clutter � Hoarding confined to a single room.
levels 5 and 914 No further consideration required.
� Hoarding in more than one room.
Hardofofoxygen
Use hearing, or partially
combined �
� Please
Oxygen specify:
use combined with smoking. Outstanding Additional
Oxygen
Hazard and
Sensory Circumstances Hoarding within
Further escape
details route.
of current Details of any existing control
sighted.
with high fire risk behaviour. risk actions
impairment
risk factors (circle as appropriate) � Other of circumstances
Types (please specify):
materials hoarded: measures
(Yes or No) required
Deaf or blind. Please specify:
None.
No oxygen used. No further consideration required.
No further consideration required.
13 Visual
Sensory imagesFully able toratings
of clutter respondare set out at the end of this appendix.
No further consideration required.
14 Visual imagesappropriately.
impairment of clutter ratingsorare set out at �the Please
end of this
useappendix. Outstanding Additional
Hazard and Hard
Oxygen
Sensory Use ofofoxygen
hearing, partially
combined
Circumstances Oxygen specify:
Further combined
details with smoking.
of current Details of any existing control
sighted.
with (circle
high fire risk behaviour. risk actions
impairment
risk factors May be slowas appropriate)
to respond. � Limited circumstances
decision-making
Other (please specify): ability. measures
(Yes or No) required
Deaf or blind. � Learning
205 Fire safety in specialised housing
difficulties.
Please specify:
Capacity of None. � Dementia. No further consideration required.
resident to
13 Fully able to respond � Please specify:
respond
Visual images of clutter ratings are set out at the end of this appendix.
Sensory No further consideration required.
14 Visual imagesappropriately.
appropriately
impairment of clutter
Hard ratingsorare
of hearing, set out at the Please
partially end of this appendix.
specify:
to fire alarm sighted.
signals or May
Unablebe to
slow to respond.
respond; would � Limited
Inability decision-making ability.
to make appropriate
signs of fire. need staff assistance. decisions.
� Learning difficulties.
205 Fire safety in specialised housing
� Severe learning difficulties.
Capacity of � Dementia.
resident to � Dementia.
13 Visual images of clutter ratings are set out at �the Please
respond
specify:
end of this appendix.
14 Visual images of clutter ratings are set out at �the Please
appropriately specify:
end of this appendix.
to fire alarm
signals or Unable to respond; would � Inability to make appropriate
Fully able.
signs of fire. need staff assistance. decisions.
205 Fire safety in specialised housing
No further consideration required.
� Severe learning difficulties.
Limited mobility, so slow to � Dementia.
Ability to evacuate the building.
Ability of evacuate.
resident to � Please
Ability tospecify:
move from the room of fire
make their origin, but not the building.
Outstanding Additional
way to and
Hazard Circumstances � AbilityFurther
to move details
awayoffrom
current
the fire, Details of any existing control
risk actions
risk factors Fully(circle
safety. able. as appropriate)
but not the circumstances
room of fire origin. measures
No further consideration required. (Yes or No) required
No mobility without Please specify:
assistance.
Limited mobility, so slow to � Ability to evacuate the building.
Ability of evacuate.
resident to � Ability
Pleasetospecify:
move from the room of fire
Other
make their origin, but not the building.
factors.
Fire safety in specialised housing 206 Outstanding Additional
way to and
Hazard Circumstances � AbilityFurther
to move details
awayoffrom
current
the fire, Details of any existing control
risk actions
safety.
risk factors (circle as appropriate) but not the circumstances
room of fire origin. measures
(Yes or No) required
No mobility without Please specify:
Risk Level assistance. Low Medium High

13
Visual images of clutter ratings are set out at the Please
end of specify:
this appendix.
Other
14
Visual images of clutter ratings are set out at the end of this appendix.
factors.
Fire safety in specialised housing 206

272 Risk Level Low Medium High

13
Visual images of clutter ratings are set out at the end of this appendix.
14
Visual images of clutter ratings are set out at the end of this appendix.

272

207 Fire safety in specialised housing

© National Fire Chiefs Council 109


PAS 79-2:2020

Annex F (informative)
Model matrix of responsibilities for fire safety
measures in specialized housing

F.1 This annex contains a matrix within which


responsibilities for various fire safety matters can
be recorded in the case of those specialized housing
premises in which there are multiple dutyholders under
the relevant fire safety legislation. It is reproduced
from Fire safety in specialised housing [3], with the
permission of the National Fire Chiefs Council. It serves
the purpose of ensuring that each dutyholder has a
clear understanding of the relevant responsibilities of
that dutyholder and every other dutyholder, thereby
ensuring that no responsibilities are overlooked
(e.g. on the incorrect assumption that duties agreed
amongst the dutyholders fall upon other dutyholders,
rather than the dutyholder in question).

F.2 Use of the matrix is particularly relevant in the


case of many supported housing premises, in which
there is a landlord, who owns the property, a housing
provider, who leases the property from the landlord, a
care provider, based on the premises, who provides the
care to residents, and, possibly, a managing agent; the
local authority commissioner of services might also have
responsibilities.

F.3 The publication Fire safety in specialised housing [3]


recommends that, other than in specialized housing
with a single dutyholder, no specialized housing be
operated without completion of a matrix of this
type, which then forms part of the record of fire
safety arrangements required by the relevant fire
safety legislation [see item k) of the Commentary on
Clause 16].

110 © The British Standards Institution 2020


PAS 79-2:2020

Aspect of fire safety management Agreed responsibilities

Owner/ Housing Managing agent Care provider Commissioner


landlord provider or facilities of services
managers (if
different from
housing provider)

Lead dutyholder8)
Building fire risk assessment
Person-centred fire risk assessment (where
appropriate)
Testing of fire alarm system
Maintenance of fire alarm system
Testing of emergency lighting
Maintenance of emergency lighting
Testing of sprinkler system
Maintenance of sprinkler system
Testing of smoke vents
Maintenance of smoke vents
Testing of door release mechanisms
Maintenance of door release mechanisms
Testing of social alarm system
Maintenance of social alarm system
Routine housekeeping inspections, including
checking fire doors, fire exit doors and condition
of fire extinguishers, etc.
Maintenance of fire doors
Maintenance of fire extinguishers
Maintenance of rising mains
Maintenance of lightning protection system
Provision of fire safety information to new
residents
Ongoing engagement with residents regarding
fire prevention
Ongoing engagement with residents to remind
them of fire procedures
Fire drills (if applicable)
Maintaining a record of the fire safety
arrangements
Ensuring that fire procedures are up to date
Liaison with local fire and rescue service crews
Training of staff
Inspections during contractors’ works
Provision of information to outside contractors
Recording false alarms
Holding of relevant records re testing
maintenance, training, drills, etc.

This is not intended to represent a legal interpretation of responsibility, but merely reflects the agreement amongst
8)

dutyholders in place for overseeing fire safety.

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PAS 79-2:2020

Annex G (informative)
Exemplar of a completed fire risk assessment

G.1 This annex contains an exemplar of the significant


findings of an FRA, documented using the pro forma in
Annex A. Its purpose is to aid clarity in the use of the
pro forma in Annex A.

G.2 For ease of study, the exemplar relates to a


fictional, quite simple, high-rise block of flats.
The exemplar is not intended to constitute a model
FRA or a counsel of perfection in relation to the level
of detail recorded, which, again, for ease of study,
has been kept to a relative minimum. Many FRAs,
particularly for more complex premises and those with
a greater number of deficiencies in fire safety, will
warrant recording of more extensive detail.

G.3 Similarly, it is not intended that wording and


phraseology comprise samples that are to be copied
in FRAs carried out by users of this PAS.

112 © The British Standards Institution 2020


PAS 79-2:2020

REGULATORY REFORM (FIRE SAFETY) ORDER 2005


FIRE RISK ASSESSMENT

Responsible person (e.g. employer) or person A&B Management Ltd


having control of the premises:

Address of premises: Derrick House, King William Estate, Anytown AN2 3BC

Person(s) consulted: C. Humphries, Caretaker

Assessor: Mr J. Jones MIFireE

Report validated by: Mr B. Black BSc (Hons) FIFireE

Date of fire risk assessment: 24 February 2020

Date of previous fire risk assessment: February 2019, by others

Suggested date for review: February 2021

This report is intended to assist you in compliance with Article 9 of the Regulatory Reform (Fire Safety)
Order 2005 (the ‘Fire Safety Order’), which requires that a risk assessment be carried out.

March 2020

PAS
© 79-2
C.S. Todd Draft 4.3
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PAS 79-2:2020

GENERAL INFORMATION

1. THE PREMISES

1.1 Number of floors at ground level and 16


above:

Number of floors entirely below ground None


level:

Floors on which car parking is provided: N/A

1.2 Number of flats: 96

1.3 Brief details of construction and approximate age of building:

A reinforced, concrete framed building, with concrete floors, external rendered brick and tiled walls, internal
blockwork walls and a flat roof. Constructed around 1990.

1.4 Occupancy:

Purpose-built, multi-storey block of flats.

2. THE OCCUPANTS

2.1 Approximate maximum number of 1


employees at any one time:

2.2 Approximate maximum number of 240 occupants of residential flats (see Section 5 below).
residents and visitors at any one time:

3. OCCUPANTS ESPECIALLY AT RISK FROM FIRE

3.1 Sleeping occupants: 240 occupants of residential flats (see Section 5 below).

3.2 Occupants in remote areas and lone Caretaker, cleaners and occasional visiting contractors.
workers:

3.3 Others: Occasional contractors.

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4. FIRE LOSS EXPERIENCE

None known.

5. OTHER RELEVANT INFORMATION

• The premises comprise a 16 storey, purpose-built block, providing ‘general needs’ accommodation in self-
contained flats. There are 96 flats, each of which is accessed from a ventilated lobby to the single staircase.
• The maximum numbers detailed in 2.2 and 3.1 have been estimated based on the size of the flats.
• The common parts comprise the ground floor entrance lobby, staircase, common service lobbies, plant rooms
and storeroom.
• This risk assessment relates to:
– Precautions required to protect the client’s employees from fire.
– Fire precautions within the common parts and other areas controlled by the client.
– Fire protection systems that are the client’s responsibility.
• One employee, the caretaker, is normally based in the premises. Cleaning operatives are also on site at various
times and the premises are subject to periodic visits by the client’s staff.
• While the occupants of the flats are ‘relevant persons’, the flats, as domestic dwellings, are outside the scope
of the Regulatory Reform (Fire Safety) Order 2005.
• The inspection was confined to the common parts, i.e. this is a Type 1 fire risk assessment as defined in the
Local Government Group’s guide, Fire Safety in Purpose-Built Blocks of Flats.
• However, efforts were made to enter a number of flats to confirm the suitability of the fire safety measures
within flats that fall within the scope of the Fire Safety Order. Flats entered were numbers 214, 212, 303, 405,
611, 755, 1201, 1610 and 1609.
• This is a ‘general needs’ block. Residents are likely to include some with various physical disabilities.

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6. RELEVANT FIRE SAFETY LEGISLATION

6.1 The following fire safety legislation applies to these premises:

Regulatory Reform (Fire Safety) Order 2005.

6.2 The above legislation is enforced by:

Surrey Fire and Rescue Authority.

6.3 Other legislation that makes significant requirements for fire precautions in these premises
[other than the Building Regulations 2010 (as amended)]:

Housing Act 2004.

6.4 The other legislation referred to above is enforced by:

Local authority.

6.5 Is there an alterations notice in force? Yes No ü

Relevant information and deficiencies observed:

None.

FIRE HAZARDS AND THEIR ELIMINATION OR CONTROL

7. ELECTRICAL SOURCES OF IGNITION

7.1 Are reasonable measures taken to prevent fires of electrical Yes ü No


origin?

7.2 More specifically:

a) Are fixed installations periodically inspected and tested? N/A Yes ü No

b) Is portable appliance testing carried out? N/A ü Yes No

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PAS 79-2:2020

Relevant information (including description of arrangements and deficiencies observed):

• The client’s policy is to subject the installations serving the common parts of the premises to periodic inspection and test
every five years, and those within tenanted flats to inspection and test every 10 years.
• There are no portable electrical appliances within the common parts.
• Inspection and testing of all electrical installations was carried out in December 2018.

8. SMOKING

8.1 Are reasonable measures taken to prevent fires as a result Yes ü No


of smoking?

8.2 More specifically:

a) Is smoking prohibited in appropriate areas? N/A Yes ü No

b) Are there suitable arrangements for those who wish to N/A Yes ü No
smoke?

c) Did the smoking policy appear to be observed at time of N/A Yes ü No


inspection?

d) Are “No smoking” signs provided in the common areas? Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

• Smoking is not permitted in the common areas.


• Not considered in relation to flats.
• A ‘No Smoking’ sign is displayed in the entrance lobby.

9. ARSON

9.1 Does basic security against arson by outsiders appear Yes ü No


reasonable1)?

9.2 Is there an absence of unnecessary fire load in close Yes ü No


proximity to the premises or available for ignition by
outsiders?

9.3 Relevant information (including description of arrangements and deficiencies observed):

• The main entrance door to the premises is fitted with an electronic door entry system, the lock of which fails safe in the
event of failure of the normal power supply, and the standby supply, to the lock.
• CCTV is installed in the entrance, in the lift and around the external areas of the building.
• The main refuse bins are located in a secure ground-floor bin chute room. Waste is removed from site on a weekly basis.
• Instances of antisocial behaviour are monitored by the client.

1) Reasonable only in the context of this fire risk assessment. If specific advice on security (including security against arson) is required,
this should be obtained from a security specialist.

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10. PORTABLE HEATERS AND HEATING AND VENTILATION INSTALLATIONS

10.1 Is there satisfactory control over the use of portable N/A ü Yes No
heaters?

10.2 Are fixed heating and ventilation installations subject to N/A ü Yes No
regular maintenance?

Relevant information (including description of arrangements and deficiencies observed):

• No heating is provided in the common parts.


• The flats are fitted with individual heating systems.

11. COOKING

11.1 Are reasonable measures taken to prevent fires as a result N/A ü Yes No
of cooking?

Relevant information (including description of arrangements and deficiencies observed):

• No cooking facilities are provided in the common parts.


• Cooking appliances in flats have not been considered.

12. LIGHTNING

12.1 Does the building have a lightning protection system? Yes ü No

Relevant information and deficiencies observed:

None.

13. HOUSEKEEPING

13.1 Is the overall standard of housekeeping adequate? Yes ü No

13.2 More specifically:

a) Do combustible materials appear to be separated from Yes ü No


ignition sources?

b) Is unnecessary accumulation or inappropriate storage of Yes ü No


combustible materials or waste avoided?

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PAS 79-2:2020

c) Are gas and electricity intake/meter cupboards N/A Yes ü No


adequately secured and kept clear of combustible
materials?

Relevant information (including description of arrangements and deficiencies observed):

The Client has adopted a ‘zero tolerance’ approach, and seeks to communicate this to the residents. The situation is
monitored by Client staff and, where applicable, by cleaners during periodic visits to the premises.

14. HAZARDS INTRODUCED BY OUTSIDE CONTRACTORS AND BUILDING WORKS

14.1 Is there satisfactory control over works carried out in the N/A Yes ü No
building by contractors?

Relevant information (including description of arrangements and deficiencies observed):

• External contractors are approved by the Client and are required to submit method statements, risk assessments and,
where necessary, arrangements for ‘hot work’.
• The ongoing monitoring of the work of external contractors and internal maintenance staff on site is subject to the
Client’s procedures and inspections.

15. DANGEROUS SUBSTANCES2)

15.1 Are the general fire precautions adequate to address the N/A ü Yes No
hazards associated with dangerous substances used or
stored within the premises3)?

Relevant information and deficiencies observed:

None.

2) For the purpose of this risk assessment and the Fire Safety Order, dangerous substances are primarily explosive, highly flammable or
flammable substances and oxidizing agents.
3) Small quantities with negligible impact on the appropriate fire precautions need not be taken into account.

16. OTHER SIGNIFICANT FIRE HAZARDS THAT WARRANT CONSIDERATION

16.1 Hazards:

None.

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Relevant information and deficiencies observed:

FIRE PROTECTION MEASURES

17. MEANS OF ESCAPE

17.1 Is the design and maintenance of the means of escape Yes No ü


considered adequate?

17.2 More specifically:

a) Are there reasonable distances of travel:

- where there is escape in a single direction? N/A Yes ü No

- where there are alternative means of escape? N/A Yes ü No

b) Is there adequate provision of exits? N/A Yes ü No

c) Do fire exits open in the direction of escape, where N/A Yes ü No


necessary?

d) Are the arrangements provided for securing exits N/A Yes ü No


satisfactory?

e) Is the fire-resisting construction (including any glazing) N/A Yes ü No


protecting escape routes and staircases of a suitable
standard and maintained in sound condition?

f) Is the fire resistance of doors to staircases and the common N/A Yes ü No
areas considered adequate, and are the doors maintained
in sound condition?

g) Are suitable self-closing devices fitted to doors in the N/A Yes ü No


common areas?

h) Is the fire resistance of doors to meter cupboards/store N/A Yes ü No


rooms/plant rooms in the common areas considered
adequate, and are they adequately secured and/or fitted
with suitable self-closing devices?

i) Is the fire resistance of flat entrance doors considered N/A Yes ü No


adequate, and are doors maintained in sound condition?

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120 © C.S. Todd & Associates Ltd
PAS 79-2:2020

j) Are suitable self-closing devices fitted to flat entrance doors N/A Yes No ü
and, where fitted, maintained in good working order?

k) Are there adequate smoke control provisions to protect the N/A Yes ü No
common escape routes, where necessary?

l) Are all escape routes clear of obstructions? N/A Yes ü No

m) Are all fire exits easily and immediately openable? N/A Yes ü No

n) Is it considered that the premises are provided with N/A Yes ü No


reasonable arrangements for means of escape for disabled
people?

Relevant information (including description of arrangements and deficiencies observed):

• This is a purpose-built block of flats, the design of which has been based on the principle of ‘stay put’, such that the
occupants of the flats, other than those in which a fire occurs, should be able to remain in their flats in relative safety
unless their flat is affected by fire or smoke or they are directed to evacuate by the fire and rescue service.
• The premises are provided with a single protected escape staircase, which is accessed on all floors from a common
protected hall/lobby.
• The staircase discharges direct to open air at ground level from the base of the staircase enclosure.
• Smoke ventilation is provided in the form of openable windows and automatically opening vents controlled by smoke
detectors in the common parts.
• The main entrance door is fitted with an electronic lock and door release button. The lock will revert to the unlocked
state in the event of a power failure.
• Flat entrance doors and doors to staircases and refuse/bin chute rooms are self-closing, timber FD30S doors, which were
installed in 2011.
• Letter boxes are present in the doors to flats, and have additional fire protection.
• Some self-closing doors were found that were not closing effectively.

18. RECORDS

18.1 Is it considered that there is/are:

a) adequate levels of compartmentation between floors and Yes ü No


between flats and the common escape routes?

b) reasonable limitation of linings to escape routes that might Yes ü No


promote fire spread?

c) as far as can reasonably be ascertained, reasonable fire N/A Yes ü No


separation within any roof space?

d) adequately fire protected service risers and/or ducts in N/A Yes ü No


common areas, that will restrict the spread of fire and
smoke?

18.2 As far as can reasonably be ascertained, are fire dampers N/A ü Yes No
provided as necessary to protect critical means of escape
against passage of fire, smoke and products of combustion in
the early stages of a fire4), 5)?

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PAS 79-2:2020

Relevant information (including description of arrangements and deficiencies observed):

• Efforts were made to sample the standard of compartmentation, but, as this was a Type 1 fire risk assessment, no
intrusive inspection was involved.
• Risers were opened and any hatches in ceilings were opened where accessible.
• There is no roof void.
• All visible service penetrations were suitably fire-stopped.

4) This fire risk assessment will not necessarily identify all minor fire stopping issues that might exist within the building. If you become
aware of other fire stopping issues, or are concerned about the adequacy of fire stopping, you may wish to consider arranging for
an invasive survey by a competent specialist.
5) A full investigation of the design of heating, ventilation and air conditioning systems is outside the scope of this fire risk assessment.

19. EMERGENCY ESCAPE LIGHTING

19.1 Has a reasonable standard of emergency escape lighting been N/A Yes ü No
provided6)?

Relevant information (including description of arrangements and deficiencies observed):

Non-maintained emergency escape lighting units have been provided throughout the common parts.

6) Based on visual inspection, but no test of illuminance levels or verification of full compliance with relevant British Standards carried
out.

20. FIRE SAFETY SIGNS AND NOTICES

20.1 Is there a reasonable standard of fire safety signs and notices? N/A Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

• These are single staircase premises and the means of escape are via the normal access and egress route. Therefore, ‘Fire
Exit’ signs are not considered necessary.
• Fire action notices have been provided in the staircase at each level.

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21. MEANS OF GIVING WARNING IN CASE OF FIRE

21.1 Is a reasonable fire detection and fire alarm system provided N/A Yes No ü
in the common areas, where necessary7)?

21.2 If there is a communal fire detection and fire alarm system, N/A ü Yes No
does it extend into the dwellings?

21.3 Where appropriate, has a fire alarm zone plan been N/A ü Yes No
provided?

21.4 Where appropriate, are there adequate arrangements for N/A ü Yes No
silencing and resetting an alarm condition?

Relevant information (including description of arrangements and deficiencies observed):

• As this is a purpose-built block of flats with a stay put strategy, no communal fire alarm system is appropriate.
• Smoke detection is provided in the common parts to operate the automatic opening vents fitted to the lobby windows.
• The smoke detection is monitored by security staff at HQ for property protection purposes.
• It is the Client’s policy to install domestic smoke alarms, as part of the void works’ specification, in tenanted flats to
provide a warning to the occupants of the flat of a fire in their own flat.

Relevant information on false alarm experience (if known):

None.

7) Based on visual inspection, but no audibility tests or verification of full compliance with relevant British Standard carried out.

22. MANUAL FIRE EXTINGUISHING APPLIANCES

22.1 Is there reasonable provision of manual fire extinguishing N/A Yes ü No


appliances?

22.2 Are all fire extinguishing appliances readily accessible? N/A Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

It is not appropriate to install fire extinguishers in the common parts of blocks of flats. There are no fire extinguishers
provided other than in plant rooms, electricity supply cupboards and the waste bin room.

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23. RELEVANT AUTOMATIC FIRE EXTINGUISHING SYSTEMS8)

23.1 Type of fixed system:

None.

Relevant information and deficiencies observed:

8) Relevant to life safety and this risk assessment (as opposed to property protection).

24. OTHER RELEVANT FIXED SYSTEMS AND EQUIPMENT9)

24.1 Type of fixed system:

• Dry rising main.


• Automatic smoke vents.
• Firefighting lift.

Relevant information and deficiencies observed:

24.2 Are there appropriately sited facilities for electrical isolation N/A ü Yes No
of any photovoltaic (PV) cells, with appropriate signage, to
assist the fire and rescue service?

Relevant information (including description of arrangements and deficiencies observed):

9) Relevant to life safety and this risk assessment (as opposed to property protection).

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MANAGEMENT OF FIRE SAFETY

25. PROCEDURES AND ARRANGEMENTS

25.1 Safety assistance:

The competent person(s) appointed under Article 18 of the Fire Safety Order to assist the
responsible person in undertaking the preventive and protective measures (i.e. relevant general fire
precautions) is:

Health and Safety Manager.

25.2 Fire safety at the premises is managed by10):

Area Building Officer.

25.3 Is there a suitable record of the fire safety arrangements? Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

• A fire safety management plan for all premises is in place and is held at HQ.
• In addition to the fire safety management plan, a site-specific fire strategy document is held by the caretaker.
• The Tenant’s Handbook contains basic fire safety advice.

25.4 Evacuation strategy

ü Stay put
Simultaneous evacuation
Other (please specify below)

Comment: This is the appropriate strategy.

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25.5 Are procedures in the event of fire appropriate and Yes ü No


properly documented, where appropriate11)?

Relevant information (including description of arrangements and deficiencies observed):

Fire plan held and key points are on fire action notices in the common parts.

25.6 Are routine in-house inspections of fire precautions N/A Yes ü No


undertaken (e.g. in the course of health and safety
inspections)?

Relevant information (including description of arrangements and deficiencies observed):

Housing Officers undertake regular inspections, which include checks of fire precautions.

10) This is not intended to represent a legal interpretation of responsibility, but merely reflects the managerial arrangement in place
at the time of this risk assessment.
11) Based on brief review of procedures at the time of this fire risk assessment. In-depth review of documentation is outside the scope
of this fire risk assessment, unless otherwise stated.

26. TRAINING AND DRILLS

26.1 Are all staff given adequate fire safety instruction and N/A Yes ü No
training?

Relevant information (including description of arrangements and deficiencies observed):

The caretaker has carried out on-line fire training in the last six months.

26.2 When the employees of another employer work in the N/A Yes ü No
premises, is appropriate information on fire risks and fire
safety measures provided?

Relevant information (including description of arrangements and deficiencies observed):

All contractors are given a fire safety briefing by the caretaker.

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27. TESTING AND MAINTENANCE

27.1 Is there adequate maintenance of the premises? Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

None.

27.2 Is weekly testing and periodic servicing of the fire detection N/A Yes ü No
and fire alarm system undertaken?

Relevant information (including description of arrangements and deficiencies observed):

Tenants are responsible for testing their own smoke alarms on a regular basis.

27.3 Are monthly and annual testing routines in place for the N/A Yes No ü
emergency escape lighting?

Relevant information (including description of arrangements and deficiencies observed):

Monthly tests of the emergency escape lighting are not being carried out.

27.4 Is annual maintenance of fire extinguishing appliances N/A Yes No ü


undertaken?

Relevant information (including description of arrangements and deficiencies observed):

Extinguishers were found to be overdue for maintenance.

27.5 Are six-monthly inspection and annual testing of rising N/A Yes ü No
mains undertaken?

Relevant information (including description of arrangements and deficiencies observed):

It is understood that the six-monthly inspection and annual testing of the dry rising main is carried out as part of the
planned preventive maintenance programme.

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27.6 Are weekly and monthly testing, six-monthly inspection, N/A Yes ü No
and annual inspection and testing undertaken of lift(s)
provided for use by firefighters or evacuation of disabled
people (evacuation lifts)?

Relevant information (including description of arrangements and deficiencies observed):

It is understood that the firefighters switch for the fire-fighting lift is tested by the caretaker every week. The lift is inspected
every six months and maintained annually by contractors.

27.7 Other relevant inspections or tests:

• Automatic and manual smoke vents.


• Lightning protection.

Relevant information (including description of arrangements and deficiencies observed):

• It is understood that the interface with the AOVs is subject to monthly testing. Smoke detection and the AOVs are
maintained every six months.
• It is understood that the annual inspection and testing of lightning protection system is carried out as part of the
planned preventive maintenance programme.

28. RECORDS

28.1 Are there appropriate records of:

a) Fire alarm tests (where relevant)? N/A Yes ü No

b) Emergency escape lighting tests? N/A Yes ü No

c) Maintenance and testing of other fire protection N/A Yes ü No


systems and equipment?

Relevant information (including description of arrangements and deficiencies observed):

It is understood that the records are held centrally by HQ.

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29. PREMISES INFORMATION BOX

29.1 Is there a suitably located premises information box for the N/A ü Yes No
fire and rescue service?12)

29.2 Are there arrangements to keep the premises information N/A ü Yes No
box up to date?12)

Relevant information (including description of arrangements and deficiencies observed):

12) Normally applicable only to sheltered and extra care housing.

30. ENGAGEMENT WITH RESIDENTS

30.1 Has information on fire procedures been disseminated to N/A Yes ü No


residents?

30.2 Is fire safety information disseminated to residents? N/A Yes ü No

Relevant information (including description of arrangements and deficiencies observed):

• Relevant information is contained in a Residents’ Handbook, which is issued to all new tenants.
• The section on fire procedures and fire safety is issued to all residents, including leaseholders, annually.
• Fire procedure notices are prominently displayed on the ground floor.

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FIRE RISK ASSESSMENT

The following simple risk level estimator is based on a commonly used risk level estimator:

Potential consequences
of fire è
Slight harm Moderate harm Extreme harm
Likelihood of fire ê

Low Trivial risk Tolerable risk Moderate risk

Medium Tolerable risk Moderate risk Substantial risk

High Moderate risk Substantial risk Intolerable risk

Taking into account the fire prevention measures observed at the time of this risk assessment, it is
considered that the hazard from fire (likelihood of fire) at these premises is:

Low Medium ü High

In this context, a definition of the above terms is as follows:

Low: Unusually low likelihood of fire as a result of negligible potential sources of


ignition.

Medium: Normal fire hazards (e.g. potential ignition sources) for this type of occupancy,
with fire hazards generally subject to appropriate controls (other than minor
shortcomings).

High: Lack of adequate controls applied to one or more significant fire hazards, such
as to result in significant increase in likelihood of fire.

Taking into account the nature of the premises and the occupants, as well as the fire protection and
procedural arrangements observed at the time of this fire risk assessment, it is considered that the
consequences for life safety in the event of fire would be:

Slight harm ü Moderate harm Extreme harm

In this context, a definition of the above terms is as follows:

Slight harm: Outbreak of fire unlikely to result in serious injury or death of any occupant.

Moderate harm: Outbreak of fire could foreseeably result in injury (including serious injury) of
one or more occupants, but is unlikely to result in multiple fatalities.

Extreme harm: Significant potential for serious injury or death of one or more occupants.

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Accordingly, it is considered that the risk to life from fire at these premises is:

Trivial Tolerable ü Moderate Substantial Intolerable

Comments:

None.

A suitable risk-based control plan should involve effort and urgency that is proportional to risk.
The following risk-based control plan is based on one advocated for general health and safety risks:

Risk level Action and timescale

Trivial No action is required, and no detailed records need be kept.

No major additional controls required. However, there might be a need for


Tolerable
improvements that involve minor or limited cost.

It is essential that efforts are made to reduce the risk. Risk reduction measures
should be implemented within a defined time period.

Moderate Where moderate risk is associated with consequences that constitute extreme
harm, further assessment might be required to establish more precisely the
likelihood of harm as a basis for determining the priority for improved control
measures.

Considerable resources might have to be allocated to reduce the risk. If the


Substantial building is unoccupied, it should not be occupied until the risk has been reduced.
If the building is occupied, urgent action should be taken.

Intolerable Building (or relevant area) should not be occupied until the risk is reduced.

Note that, although the purpose of this section is to place the fire risk in context, the above
approach to risk assessment is subjective and for guidance only. All hazards and deficiencies
identified in this report should be addressed by implementing all recommendations contained in
the following action plan. The fire risk assessment should be repeated regularly.

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ACTION PLAN

It is considered that the following actions should be implemented in order to reduce fire risk to, or
maintain it at, the following level:

Trivial Tolerable ü

Definition of priorities (where applicable):

Priorities:

1. High.
2. Medium.
3. Low.

Suggested timescale:

A. Immediately.
B. Short term.
C. Medium term.
D. Long term.

Item Recommendation Priority Timescale

1. The emergency escape lighting should be subject to a monthly test, 2 A


and annual servicing and test, in accordance with the requirements of
BS 5266-8.

2. The door onto the staircase on the 9th floor was not closing fully into 2 B
its frame. The self-closing device should receive attention to ensure
that it operates effectively and closes the door fully into its frame.

3. The door onto the 6th floor lobby was not closing fully into its frame. 2 B
The self-closing device should receive attention to ensure that it
operates effectively and closes the door fully into its frame.

4. The servicing of the portable fire extinguishers located in the electrical 2 B


intake room was found to be overdue. It should be ensured that all
portable firefighting equipment is serviced and maintained annually in
accordance with the recommendations BS 5306-3.

Interim measures (where appropriate)

5. None

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REFERENCES
[It is normal practice for the FRA to include a list of relevant references.]

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Bibliography

Standards publications BS 8414-2, Fire performance of external cladding


systems – Part 2: Test method for non-loadbearing
For dated references, only the edition cited applies. external cladding systems fixed to, and supported by, a
For undated references, the latest edition of the structural steel frame
referenced document (including any amendments)
applies. BS 8629, Code of practice for the design, installation,
commissioning and maintenance of evacuation alert
BS 2655 (all parts), Specification for lifts, escalators, systems for use by fire and rescue services in buildings
passenger conveyors and paternosters containing flats

BS 5266-1, Emergency lighting – Part 1: Code of BS 8899:2016, Improvement of fire-fighting and


practice for the emergency lighting of premises evacuation provisions in existing lifts – Code of practice

BS 5306-3, Fire extinguishing installations and BS 9251, Fire sprinkler systems for domestic and
equipment on premises – Part 3: Commissioning and residential occupancies – Code of practice
maintenance of portable fire extinguishers – Code of
practice BS 9991:2015, Fire safety in the design, management
and use of residential buildings – Code of practice
BS 5499-4, Safety signs – Part 4: Code of practice for
escape route signing BS 9997, Fire risk management systems – Requirements
with guidance for use
BS 5499-10, Guidance for the selection and use of
safety signs and fire safety notices BS EN 54, Fire detection and fire alarm systems

BS 5588-5 (withdrawn), Fire precautions in the design, BS EN 81-72:2020, Safety rules for the construction
construction and use of buildings – Part 5: Access and and installation of lifts –Particular applications
facilities for fire-fighting for passenger and goods passenger lifts –
Part 72: Firefighters lifts
BS 5655 (all parts), Lifts and service lifts
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BS 5839-1, Fire detection and fire alarm systems
for buildings – Part 1: Code of practice for design, BS EN 13501-1:2007+A1:2009, Fire classification
installation, commissioning and maintenance of of construction products and building elements –
systems in non-domestic premises Part 1: Classification using data from reaction to fire tests

BS 7273-4, Code of practice for the operation of fire BS EN 50172 (BS 5266-8), Emergency escape lighting
protection measures – Part 4: Actuation of release systems
mechanisms for doors
BS EN ISO 7010, Graphical symbols – Safety colours and
BS 7671, Requirements for Electrical Installations – safety signs – Registered safety signs
IET Wiring Regulations
BS ISO 23601, Safety identification – Escape and
BS 7974:2019, Application of fire safety engineering evacuation plan signs
principles to the design of buildings – Code of practice
PAS 79-1, Fire risk assessment – Part 1: Premises other
BS 8414-1, Fire performance of external cladding than housing – Code of practice
systems – Part 1: Test method for non-loadbearing
external cladding systems fixed to, and supported by, a PAS 9980, Fire risk appraisal and assessment of external
masonry substrate wall construction of existing blocks of flats – Code of
practice9)

9)
In preparation.

134 © The British Standards Institution 2020


PAS 79-2:2020

Other publications [12] SCOTTISH GOVERNMENT. Practical fire safety


guidance for existing premises with sleeping
[1] LOCAL GOVERNMENT ASSOCIATION (LGA). Fire accommodation. Edinburgh: Scottish Government,
safety in purpose-built blocks of flats. London: 2017.
LGA, 2012.10)
[13] NORTHERN IRELAND. Fire and Rescue Services
[2] SCOTTISH GOVERNMENT. Practical fire safety (Northern Ireland) Order 2006. Belfast: The
guidance for existing high rise domestic buildings. Stationery Office.
Edinburgh, Scottish Government, 2019.11)
[14] NORTHERN IRELAND. Fire Safety Regulations
[3] NATIONAL FIRE CHIEFS COUNCIL (NFCC). Fire (Northern Ireland) 2010. Belfast: The Stationery
safety in specialised housing – Guidance. London: Office.
NFCC, 2017.12)
[15] NORTHERN IRELAND. Houses in Multiple
[4] SCOTTISH GOVERNMENT. Practical fire safety Occupation (Northern Ireland) Act 2016. Belfast:
guidance for existing specialised housing and The Stationery Office.
similar premises. Edinburgh: Scottish Government,
2020. [16] DEPARTMENT OF HEALTH, SOCIAL SERVICES
AND PUBLIC SAFETY. Fire safety risk assessment –
[5] GREAT BRITAIN. Regulatory Reform (Fire Safety) Sleeping accommodation. Belfast: The Stationery
Order 2005 (as amended). London: The Stationery Office, 2013.
Office.
[17] FIRE INDUSTRY ASSOCIATION (FIA). Fire risk
[6] DEPARTMENT FOR COMMUNITIES AND LOCAL assessors – Standard scope of services. Hampton:
GOVERNMENT (DCLG). Fire safety – Risk FIA, 2014.
assessment – Sleeping accommodation. London:
The Stationery Office, 2006. [18] DEPARTMENT FOR COMMUNITIES AND LOCAL
GOVERNMENT. Building a safer future –
[7] LOCAL AUTHORITY COORDINATORS OF Independent review of building regulations and
REGULATORY SERVICES (LACoRS). Housing – fire safety: Final report. Crown Copyright, 2018.13)
Fire safety – Guidance on fire safety provisions
for certain types of existing housing. London: [19] HEALTH AND SAFETY EXECUTIVE. Good practice
LACoRS, 2008. and pitfalls in risk assessment. Research
Report 151. Sudbury: HSE Books, 2003.
[8] SCOTLAND. Fire (Scotland) Act 2005. Edinburgh:
The Stationery Office. [20] INSTITUTION OF ENGINEERING AND TECHNOLOGY
(IET). Inspection and testing. Guidance Note 3.
[9] SCOTLAND. Fire Safety (Scotland) Eighth edition. Stevenage: IET, 2018.
Regulations 2006. Edinburgh: The Stationery
Office. [21] MINISTRY OF HOUSING, COMMUNITIES AND
LOCAL GOVERNMENT. The Building Regulations
[10] GREAT BRITAIN. Civic Government (Scotland) Act 2010 – Approved Document B: Fire safety –
1982. London: HMSO. Volume 1: Dwellings. 2019 edition for use in
England. Crown Copyright, 2019.
[11] SCOTLAND. Housing (Scotland) Act 2006.
Edinburgh: The Stationery Office. [22] GREAT BRITAIN. Building Regulations 2010.
London: The Stationery Office.

10)
Available from https://www.local.gov.uk/sites/default/files/documents/fire-safety-purpose-built-04b.pdf. Under revision at the
time of publication of this PAS.
11)
Online publication only, available at http://www.firelawscotland.org/.
12)
Available from https://www.nationalfirechiefs.org.uk/write/MediaUploads/NFCC%20Guidance%20publications/NFCC_
Specialised_Housing_Guidance_-_Copy.pdf.
13)
Available from https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/707785/
Building_a_Safer_Future_-_web.pdf

© The British Standards Institution 2020 135


PAS 79-2:2020

[23] SCOTLAND. Fire safety design summary 2017. [34] FIRE INDUSTRY ASSOCIATION (FIA). Guidance
Edinburgh: Scottish Government, 2017. on the issue of cladding and external wall
construction in fire risk assessments for multi-
[24] SCOTLAND. Building (Procedure) (Scotland) occupied residential premises. Hampton: FIA,
Regulations 2004 (as amended). London: The 2020.
Stationery Office.
[35] GREAT BRITAIN. Control of Asbestos Regulations
[25] GREAT BRITAIN. Dangerous Substances and 2012. London: The Stationery Office.
Explosive Atmospheres Regulations 2002 (DSEAR).
London: The Stationery Office. [36] NATIONAL FIRE CHIEFS COUNCIL (NFCC). Mobility
scooter guidance for residential buildings.
[26] NORTHERN IRELAND FIRE & RESCUE SERVICE Birmingham: NFCC, 2018.
(NIFRS). HMO fire safety guide – Information
on complying with fire safety law in Northern
Ireland. Belfast: NIFRS, 2019.

[27] SCOTTISH BUILDING STANDARDS. Building


Standards Technical Handbook 2019 – Domestic –
Section 2: Fire. Edinburgh: Scottish Government,
2019.

[28] NORTHERN IRELAND DEPARTMENT OF FINANCE


AND PERSONNEL. The Building Regulations
(Northern Ireland) 2012 Guidance – Technical
Booklet E: Fire safety. Belfast: The Stationery
Office, 2012.

[29] MINISTRY OF HOUSING, COMMUNITIES AND


LOCAL GOVERNMENT (MHCLG). The Smoke and
Carbon Monoxide Alarm (England) Regulations
2015: Q&A booklet for the private rented sector –
Landlords and tenants. London: MHCLG, 2015.

[30] SCOTTISH GOVERNMENT. Fire detection in private


rented properties: Guidance. Edinburgh: Scottish
Government, 2019.

[31] MINISTRY OF HOUSING, COMMUNITIES AND


LOCAL GOVERNMENT (MHCLG). Advice for
building owners of multi-storey, multi-occupied
residential buildings. London: MHCLG, 2020.14)

[32] GREAT BRITAIN. Health and Safety (Safety Signs


and Signals) Regulations 1996. London: HMSO.

[33] SCOTLAND. Building (Scotland) Regulations 2004


(as amended). Edinburgh: The Stationery Office.

Available from https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/869532/


14)

Building_safety_advice_for_building_owners_including_fire_doors_January_2020.pdf

136 © The British Standards Institution 2020


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