A follow-up to our guide on UK fire safety regulations, looking at what separates a compliance document from a practical fire safety management tool.
Fire Risk Assessments: Why Having One Is Not Always Enough
A follow-up to our guide on UK fire safety regulations, looking at what separates a compliance document from a practical fire safety management tool.
Most organisations know they need a Fire Risk Assessment.
Fewer stop to ask whether the one they have is genuinely useful.
A Fire Risk Assessment should not simply confirm that a report exists. It should help the Responsible Person understand the live fire risk within their premises, what evidence has been reviewed, what gaps remain, who owns each action, and what needs to happen next.
Table of Contents
- Why Fire Risk Assessments need to be useful, not just present
- What does a suitable and sufficient FRA actually mean?
- Compliance-led FRA vs operationally focused FRA
- Why current occupancy and building use matter
- The importance of evidence, records and specific findings
- Landlord and tenant responsibilities in multi-occupied buildings
- What a useful FRA action plan should include
- Comparison grid: basic assurance vs stronger assurance
- Questions every Responsible Person should ask about their FRA
- Final thoughts
Why Fire Risk Assessments need to be useful, not just present
The existence of a Fire Risk Assessment is not, by itself, the end point.
The value of the assessment sits in the quality of the findings, the evidence reviewed, the clarity of the responsibilities and the usefulness of the action plan.
A Fire Risk Assessment should help answer practical questions:
Can people escape safely?
Are fire protection systems being maintained?
Are defects being identified and closed out?
Are landlord and tenant responsibilities clear?
Has current occupancy been considered?
Are vulnerable people, visitors and lone workers accounted for?
Is the action plan specific enough for the facilities team to act on?
If those questions remain unclear after reading the report, the organisation may have a document, but not necessarily meaningful assurance.
What does a suitable and sufficient FRA actually mean?
A suitable and sufficient Fire Risk Assessment should reflect the premises as they are currently used.
It should consider the people who may be affected, the fire hazards present, the general fire precautions in place and the management arrangements needed to keep people safe.
For employers, building occupiers and Responsible Persons, this means looking beyond whether an FRA has been completed and asking whether it properly reflects current risk.
This is particularly important where there have been changes such as:
- increased occupancy
- changes to layout or fit-out
- new working patterns
- new equipment or processes
- changes to landlord or managing agent arrangements
- changes to building systems
- shared occupancy with other tenants
- changes in staff or visitor profiles
An FRA completed at an earlier stage of occupation may have been appropriate at the time. But once the premises are fully occupied and operational, the risk profile may be different.
That is why the Responsible Person must ensure the assessment remains current, relevant and capable of supporting effective fire safety management.
Compliance-led FRA vs operationally focused FRA?
A compliance-led FRA may confirm that an assessment has been completed and identify broad areas for review or improvement.
That has value.
However, an operationally focused FRA should go further.
It should help the Responsible Person, facilities team and leadership understand the live fire risk within the premises. It should identify what evidence has been reviewed, what remains outstanding, what has changed, who owns each control and what action is required next.
For example, a compliance-led finding may say:
“Emergency lighting records should be reviewed.”
An operationally focused finding should be more specific:
“Emergency lighting test records were reviewed. Specific units were identified as failed or not charging. Evidence of repair was not available at the time of assessment. These should be reported, rectified and evidence retained.”
That difference matters.
One is a general recommendation.
The other can be turned into an action, assigned to a person, followed up with a contractor and closed out with evidence.
Why current occupancy and building use matter
Fire risk is not assessed in isolation. It is assessed in relation to the premises and the people who may be affected.
That means occupancy matters.
A broad occupancy figure may provide a high-level indication, but a stronger FRA should consider how the premises are actually used.
This includes:
- the number of employees likely to be present
- visitor numbers
- lone working
- out-of-hours access
- shared building occupancy
- whether occupants are familiar with the premises
- whether anyone may need assistance to evacuate
- how different floors or areas are used
- whether escape routes remain suitable for actual use
In one of the assessments reviewed, the premises were described with broad building details, occupied floors, maximum occupants and escape route arrangements. The later assessment provided a fuller operational picture, including current tenant occupation, staff numbers, shared building occupancy, 24/7 access, landlord arrangements and a more detailed description of construction, layout and fire safety systems.
That level of detail helps the Responsible Person understand the building as it is actually being used, not just as a static physical space.
The importance of evidence, records and specific findings
A strong Fire Risk Assessment should not simply record whether a control exists.
It should consider whether there is evidence that the control is effective.
For example:
Are fire alarm systems maintained?
Are emergency lighting tests documented?
Have failed items been repaired?
Are extinguishers suitable and serviced?
Are fire doors inspected?
Are fire dampers tested?
Is fire stopping evidenced?
Are escape routes clear?
Are action points from previous assessments closed?
Are landlord-managed systems supported by records?
Evidence is what turns assumption into assurance.
Without evidence, a Responsible Person may be relying on good faith rather than demonstrable control.
This is particularly important where systems are managed by a landlord, managing agent or external contractor. The tenant or occupier may not directly control those systems, but they still need sufficient assurance that they are being maintained and that any defects are being addressed.
Landlord and tenant responsibilities in multi-occupied buildings
Fire safety in a multi-occupied building depends on cooperation.
The tenant may control its own occupied space, but the landlord or managing agent may control shared areas, common escape routes, fire alarm systems, emergency lighting, risers, plant areas, lifts, fire dampers, fire curtains and other building-wide controls.
A useful FRA should make those interfaces clear.
It should help the Responsible Person understand:
- which systems are under tenant control
- which systems are landlord-managed
- what evidence has been provided by the landlord or managing agent
- what information is still outstanding
- whether shared procedures are understood
- whether the tenant’s arrangements align with building-wide fire procedures
- whether other occupiers could affect the fire risk
In the SG assessment, the report explicitly notes that the assessment concerns the tenanted areas and recommends coordination with other occupiers so that there are no conflicts and building policies remain consistent. It also refers to landlord-managed systems and information from the assistant building manager.
That is important because blurred responsibility creates risk.
In fire safety, “we assumed someone else was dealing with it” is not a strong position.
What a useful FRA action plan should include
The action plan is often where the real value sits.
A good action plan should not leave the Responsible Person guessing.
It should be:
- clear
- specific
- proportionate
- prioritised
- assignable
- evidence-based
- capable of being tracked
- capable of being closed out
A vague action such as “review signage” is far less useful than a finding that explains which sign is unclear, where it is located and what should be changed.
A vague action such as “check fire stopping” is less useful than a finding that explains whether fire stopping was labelled, certified, evidenced or in need of further survey.
A vague action such as “confirm emergency lighting records” is less useful than a finding that identifies the test record reviewed, the failures recorded, whether repairs were evidenced and what follow-up is required.
The purpose of an action plan is not simply to list concerns.
It is to help the organisation act.
Comparison grid: basic assurance vs stronger assurance
| Area reviewed | Compliance-led FRA | Operationally focused FRA | Why it matters |
|---|---|---|---|
| Overall purpose | Provides a formal record that an assessment has been completed. | Provides a practical risk management tool for the Responsible Person, facilities team and leadership. | An FRA should help people make better fire safety decisions, not just sit in a folder. |
| Premises context | Describes the premises and broad escape arrangements. | Explains how the premises are currently used, occupied and managed. | Fire risk changes depending on real occupancy, layout, access and working patterns. |
| Timing and relevance | May reflect the premises at an earlier or transitional stage. | Reflects the current operational condition of the premises. | An FRA can become outdated when occupation, use, layout or building arrangements change. |
| Legislative framing | Refers to core fire safety compliance requirements. | Aligns the assessment to current fire safety duties, including clearer recording expectations and Responsible Person obligations. | The Responsible Person needs to understand the duties behind the findings. |
| Methodology | Uses a structured checklist or report format. | Uses a more detailed PAS 79-style approach with supporting narrative and evidence. | A stronger methodology provides context and is easier to defend under scrutiny. |
| Responsible Person clarity | Identifies who has control of the premises. | Identifies the Responsible Person, people consulted, assessor details and landlord or tenant interfaces. | In multi-occupied buildings, unclear responsibility can lead to gaps. |
| Occupancy | Uses broad maximum occupant figures. | Considers likely numbers, staff, visitors, lone working, 24/7 access and shared building occupancy. | Fire precautions must be judged against the people actually using the space. |
| Landlord and tenant responsibilities | May refer to the building or premises generally. | Separates what sits with the tenant from what sits with the landlord or managing agent. | The tenant may not control every system, but still needs assurance that those systems are effective. |
| Evidence reviewed | May highlight that records are missing or required. | Records what evidence was available, what was reviewed and what remains outstanding. | Evidence turns assumption into assurance. |
| Findings | Identifies broad issues or areas requiring confirmation. | Identifies specific defects, locations, records, systems and follow-up requirements. | Specific findings can be assigned, costed, tracked and closed out. |
| Action plan | Gives recommendations for improvement or further evidence. | Provides practical actions that facilities teams can convert into work orders. | A vague action can sit unresolved. A specific action can be owned. |
| Multi-occupancy coordination | May describe the shared building context. | Actively considers coordination with other Responsible Persons, managing agents and shared systems. | Fire safety in shared buildings depends on cooperation, not assumptions. |
| Management value | Useful as a compliance record. | Useful as an operational management document. | Stronger reports help leaders understand risk, priority and accountability. |
| Overall assurance | Shows that a Fire Risk Assessment has been undertaken. | Shows what is working, what is missing, what is uncertain and what needs to happen next. | That is the difference between having a report and having usable assurance. |
Questions every Responsible Person should ask about their FRA
If you already have a Fire Risk Assessment, ask yourself:
Does it reflect the building as it is used today?
Does it identify the Responsible Person clearly?
Does it explain who was consulted?
Does it distinguish between tenant and landlord responsibilities?
Does it consider current occupancy, visitors and lone working?
Does it identify evidence that was reviewed?
Does it highlight evidence that is missing?
Does it identify specific defects, or only broad categories?
Can the action plan be assigned to named people or teams?
Can actions be tracked and closed?
Would the report help the facilities team raise clear work orders?
Would the report stand up to scrutiny after an incident?
If the answer to several of these questions is unclear, the FRA may need to be reviewed.
Final thoughts
A Fire Risk Assessment should not leave an organisation with a file.
It should leave the organisation with clarity.
Clarity on risk.
Clarity on evidence.
Clarity on responsibility.
Clarity on action.
And, most importantly, clarity on how people will be protected if something goes wrong.
The real test is not simply:
“Do we have a Fire Risk Assessment?”
The better question is:
“Does our Fire Risk Assessment help us manage fire risk in practice?”
Fire safety is not paperwork for the sake of paperwork.
It is practical control, evidence and action.
And that is where a good Fire Risk Assessment earns its value.
