PAS 79-2 (2020) Download - Fire Risk Assessment - Housing
PAS 79-2 (2020) Download - Fire Risk Assessment - Housing
PAS 79-2 (2020) Download - Fire Risk Assessment - Housing
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
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
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.
• 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.
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”.
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.
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)
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.
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.
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 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.
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.
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.
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
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.
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
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.
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.
6)
Available at http://www.cfoa.org.uk/19532
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
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.
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
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’.”
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.
Figure 2 – Decision tree for action plan when existing premises do not conform to current
standards
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).
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;
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.
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.
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”.
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
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.
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
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.
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
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
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.
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.
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:
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),
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).
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
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.
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;
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
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;
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.
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
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
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.
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.
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.
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.
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.
Address of premises:
Person(s) consulted:
Assessor:
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]
70
PAS 79-2:2020
GENERAL INFORMATION
1.4 Occupancy:
3.3 Others:
71
PAS 79-2:2020
72
PAS 79-2:2020
6.3 Other legislation that makes significant requirements for fire precautions in these premises
[other than the Building Regulations 2010 (as amended)]:
73
PAS 79-2:2020
b) Are there suitable arrangements for those who wish to N/A Yes No
smoke?
74
PAS 79-2:2020
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.
10.1 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?
11.1 Are reasonable measures taken to prevent fires as a result of N/A Yes No
cooking?
75
PAS 79-2:2020
14.1 Is there satisfactory control over works carried out in the N/A Yes No
building by contractors?
76
PAS 79-2:2020
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)?
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.
16.1 Hazards:
77
PAS 79-2:2020
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?
m) Are all fire exits easily and immediately openable? N/A Yes No
78
PAS 79-2:2020
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)?
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.
19.1 Has a reasonable standard of emergency escape lighting been N/A Yes No
provided6)?
79
PAS 79-2:2020
6) Based on visual inspection, but no test of illuminance levels or verification of full compliance with relevant British Standards carried
out.
20.1 Is there a reasonable standard of fire safety signs and notices? N/A Yes No
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?
7) Based on visual inspection, but no audibility tests or verification of full compliance with relevant British Standard carried out.
80
PAS 79-2:2020
22.2 Are all fire extinguishing appliances readily accessible? N/A Yes No
8) Relevant to life safety and this risk assessment (as opposed to property protection).
81
PAS 79-2:2020
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?
9) Relevant to life safety and this risk assessment (as opposed to property protection).
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:
82
PAS 79-2:2020
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)?
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)?
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.
26.1 Are all staff given adequate fire safety instruction and training? N/A Yes No
83
PAS 79-2:2020
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?
27.2 Is weekly testing and periodic servicing of the fire detection N/A Yes No
and fire alarm system undertaken?
27.3 Are monthly and annual testing routines in place for the N/A Yes No
emergency escape lighting?
84
PAS 79-2:2020
27.5 Are six-monthly inspection and annual testing of rising mains N/A Yes No
undertaken?
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)?
85
PAS 79-2:2020
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)
86
PAS 79-2:2020
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
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:
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: 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.
87
PAS 79-2:2020
Accordingly, it is considered that the risk to life from fire at these premises is:
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:
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.
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.
88
PAS 79-2:2020
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
1.
2.
3.
89
PAS 79-2:2020
REFERENCES
[It is normal practice for the FRA to include a list of relevant references.]
90
PAS 79-2:2020
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.
Annex C (normative)
Key factors to consider in assessment
of means of escape
93
PAS 79-2:2020
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
Annex D (informative)
Model pro forma for documentation of a
review of an existing fire risk assessment
Address of premises:
Person(s) consulted:
Assessor:
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.
GENERAL INFORMATION
1. Significant changes identified since the time of the previous fire risk assessment in respect
of:
1.1 The premises:
2. Significant changes in measures to prevent fire since the time of the fire risk assessment:
97
PAS 79-2:2020
5.1 Significant changes in fire protection measures since the time of the fire risk assessment:
98
PAS 79-2:2020
9.1 Are there adequate fire safety signs and notices? Yes No
99
PAS 79-2:2020
100
PAS 79-2:2020
13.1 Significant changes in management of fire safety since the time of the fire risk assessment:
101
PAS 79-2:2020
16.1 Are the arrangements for staff training and fire drills Yes No
adequate?
102
PAS 79-2:2020
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:
Yes No
1.
104
PAS 79-2:2020
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
1.
Annex E (informative)
Model pro forma for a person-centred
fire risk assessment
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
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):
270
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
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.
None.
Fire Safety in Specialised Housing
No further consideration required.
Alcohol or drug use, with no
other high fire risk behaviour.
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.
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
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
Annex F (informative)
Model matrix of responsibilities for fire safety
measures in specialized housing
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)
Annex G (informative)
Exemplar of a completed fire risk assessment
Address of premises: Derrick House, King William Estate, Anytown AN2 3BC
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
& Associates Ltd 34 © The British Standards Institution 2020 113
PAS 79-2:2020
GENERAL INFORMATION
1. THE PREMISES
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:
2. THE OCCUPANTS
2.2 Approximate maximum number of 240 occupants of residential flats (see Section 5 below).
residents and visitors at any one time:
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:
None known.
• 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.
6.3 Other legislation that makes significant requirements for fire precautions in these premises
[other than the Building Regulations 2010 (as amended)]:
Local authority.
None.
• 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
b) Are there suitable arrangements for those who wish to N/A Yes ü No
smoke?
9. ARSON
• 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.
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?
11. COOKING
11.1 Are reasonable measures taken to prevent fires as a result N/A ü Yes No
of cooking?
12. LIGHTNING
None.
13. HOUSEKEEPING
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.
14.1 Is there satisfactory control over works carried out in the N/A Yes ü No
building by contractors?
• 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.
15.1 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)?
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.
16.1 Hazards:
None.
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?
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?
m) Are all fire exits easily and immediately openable? N/A Yes ü No
• 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
18.2 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)?
• 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.
19.1 Has a reasonable standard of emergency escape lighting been N/A Yes ü No
provided6)?
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.
20.1 Is there a reasonable standard of fire safety signs and notices? N/A Yes ü No
• 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.
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?
• 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.
None.
7) Based on visual inspection, but no audibility tests or verification of full compliance with relevant British Standard carried out.
22.2 Are all fire extinguishing appliances readily accessible? N/A Yes ü No
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.
None.
8) Relevant to life safety and this risk assessment (as opposed to property protection).
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?
9) Relevant to life safety and this risk assessment (as opposed to property protection).
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:
• 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.
ü Stay put
Simultaneous evacuation
Other (please specify below)
Fire plan held and key points are on fire action notices in the common parts.
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.
26.1 Are all staff given adequate fire safety instruction and N/A Yes ü No
training?
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?
None.
27.2 Is weekly testing and periodic servicing of the fire detection N/A Yes ü No
and fire alarm system undertaken?
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?
Monthly tests of the emergency escape lighting are not being carried out.
27.5 Are six-monthly inspection and annual testing of rising N/A Yes ü No
mains undertaken?
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.
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)?
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.
• 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
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 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.
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
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:
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: 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.
Accordingly, it is considered that the risk to life from fire at these premises is:
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:
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.
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.
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
Priorities:
1. High.
2. Medium.
3. Low.
Suggested timescale:
A. Immediately.
B. Short term.
C. Medium term.
D. Long term.
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.
5. None
REFERENCES
[It is normal practice for the FRA to include a list of relevant references.]
Bibliography
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maintenance of portable fire extinguishers – Code of
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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
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