A fire risk assessment that identifies obvious hazards but assigns no one to correct them is not a compliance system. Fire risk assessment responsibility sits with the person or organisation that controls the premises, but effective compliance depends on clear duties across estates, facilities, project and operational teams.
For UK dutyholders, the central issue is not simply whether an assessment exists. It is whether the assessment is suitable and sufficient, its findings are acted on, and the fire precautions remain effective as buildings, occupancy and work activities change.
Who holds fire risk assessment responsibility?
In England and Wales, the Regulatory Reform (Fire Safety) Order 2005 places duties on the Responsible Person. This is usually the employer where the workplace is under their control. In other circumstances, it may be the building owner, landlord, managing agent, facilities manager or any person with control over all or part of the premises.
The Responsible Person must take general fire precautions to ensure, so far as is reasonably practicable, the safety of employees and relevant persons. Relevant persons include visitors, contractors, residents and members of the public who may lawfully be on or near the premises.
The exact dutyholder arrangement depends on the occupation and control of the building. A single occupier with full control may have a straightforward position. A multi-let commercial property is more complex: the landlord or managing agent may control common parts, while each tenant controls its demised area. Fire safety measures must work across those boundaries, particularly where means of escape, alarm systems, risers, plant rooms and compartmentation are shared.
Scotland has separate fire safety legislation, principally under the Fire (Scotland) Act 2005 and associated regulations. Northern Ireland operates under its own fire safety order. The duty to assess risk, maintain precautions and protect relevant persons remains broadly familiar, but organisations operating across the UK should confirm the applicable legislative framework rather than applying an England and Wales procedure by default.
Responsibility cannot be fully outsourced
A competent external assessor can undertake the inspection, produce the fire risk assessment and advise on priorities. That appointment does not transfer the Responsible Person’s legal duty to ensure adequate fire safety arrangements are in place.
This distinction matters where reports identify overdue actions. A recommendation to replace defective fire doors, seal service penetrations, revise an evacuation procedure or test emergency lighting is not closed when the report is issued. It requires an owner, a budget, a target date, evidence of completion and, where necessary, verification that the measure performs as intended.
What the Responsible Person must do
The assessment must identify fire hazards, people at risk and the adequacy of existing precautions. It should then determine the further measures required to reduce risk. In practice, this means considering ignition sources, combustible materials, oxygen sources, detection and warning, escape routes, emergency lighting, signage, fire doors, compartmentation, firefighting equipment, training and management arrangements.
A suitable and sufficient assessment is proportionate to the premises and the people using it. A small, low-risk office does not require the same depth of analysis as a care setting, high-rise residential building, industrial process area, warehouse, school or complex mixed-use development. However, low complexity is not a reason for generic paperwork. The assessment must reflect the building as operated.
The Responsible Person must also provide appropriate information, instruction and training to employees. This includes action on discovering a fire, alarm response, evacuation arrangements, reporting defects and any role-specific duties for fire wardens, marshals or incident teams. Contractors need equivalent clarity, particularly where hot works, temporary power, combustible waste, altered escape routes or impairment of fire systems are involved.
Where five or more people are employed, the Responsible Person must record significant findings, the fire safety measures identified and details of people especially at risk. Written records are also essential for demonstrating due diligence to insurers, enforcing authorities, clients and auditors.
Appointing a competent fire risk assessor
Competence is not a job title or a generic health and safety qualification. It requires sufficient training, experience, knowledge and other qualities to assess the premises type and the risks present. The assessor should understand relevant fire safety legislation, building construction, human behaviour in fire, means of escape, active and passive fire protection, and the limits of their own expertise.
For routine commercial premises, an experienced competent assessor may be appropriate. More complex buildings may require specialist input from fire engineers, building surveyors, electrical specialists or passive fire protection inspectors. This is particularly relevant where there are sleeping risks, unusual evacuation strategies, heritage constraints, complex compartmentation, significant process hazards or vulnerable occupants.
The report should make the scope clear. A Type 1 to Type 4 fire risk assessment approach is commonly used for residential blocks, with intrusive inspection increasing across the types. The assessor must state what was and was not inspected, as limitations can materially affect the conclusions. A non-intrusive assessment cannot confirm the condition of concealed cavity barriers, fire stopping behind ceilings or hidden structural protection.
For higher-risk residential buildings, the Fire Safety (England) Regulations 2022 and the Building Safety Act regime introduce further management and information duties. In-scope higher-risk buildings may also require a fire risk appraisal of external walls, commonly referred to as FRAEW, where façade construction could contribute to fire spread. This work should be commissioned only where the building’s risk profile and applicable guidance indicate that it is necessary.
Turning findings into managed actions
A fire risk assessment should feed directly into a live action plan. Vague phrases such as “monitor”, “consider” or “review as necessary” are not enough where a material defect has been identified. Each action should state the risk addressed, responsible person, priority, target completion date and required evidence.
A practical action tracker will distinguish between immediate life-safety controls and longer-term improvement works. For example, wedged-open fire doors on an escape route may require immediate intervention. Replacement of a fire alarm panel may need procurement, design, installation and commissioning, but interim controls must be considered while that work proceeds.
Facilities teams should retain records of routine checks, planned preventative maintenance, alarm tests, emergency lighting tests, extinguisher servicing, fire-door inspections, evacuation drills and staff training. These records show that controls are being maintained rather than assumed to work.
Responsibility must also be coordinated with contractors. Under CDM 2015, construction work can alter compartment lines, disable detection, obstruct escape routes and introduce ignition sources. The client, principal designer, principal contractor and contractors should address temporary fire arrangements through pre-construction information, construction phase planning, RAMS, permit-to-work arrangements and site inspections. On occupied premises, the building Responsible Person must be engaged before works affect fire precautions.
When must a fire risk assessment be reviewed?
There is no safe approach based solely on renewing the assessment every one, two or three years. The assessment must be reviewed regularly and whenever there is reason to suspect it is no longer valid or there has been a significant change.
Triggers include alterations to the building, changed use or occupancy, new plant or processes, a fire or near miss, modified escape routes, changes to vulnerable persons, enforcement action, recurring defects or evidence that an evacuation drill has failed. A significant change may be operational rather than structural. Moving to night working, storing additional combustible stock or employing staff who require personal emergency evacuation plans can change the risk materially.
Formal periodic review remains good practice because buildings drift from their original arrangements. Fire doors are damaged, storage accumulates in corridors, service penetrations are opened for new installations and staff turnover erodes emergency competence. A review should test the condition and effectiveness of controls on site, not merely update a report date.
Common gaps in dutyholder arrangements
The most persistent failures arise at interfaces: landlord and tenant, building management and occupier, project team and facilities team, or assessor and action owner. A carefully written report cannot resolve unclear control of common parts or a maintenance contractor that has not been given a defined inspection regime.
Other frequent gaps include incomplete fire-door programmes, no evidence of compartmentation inspections, evacuation plans that do not account for mobility-impaired occupants, and fire safety actions left open because capital expenditure has not been authorised. These are governance issues as much as technical ones.
Directors and senior managers should therefore receive concise assurance information: outstanding high-risk actions, overdue statutory maintenance, trends from inspections, training completion, drill outcomes and any changes requiring specialist assessment. This creates a defensible route from site-level findings to accountable decision-making.
A competent assessment is the starting point, not the finish line. Clear ownership, verified corrective actions and routine assurance give the Responsible Person the evidence needed to protect people and keep the premises operationally ready.