1 Scope

This British Standard gives recommendations and corresponding examples of documentation for undertaking, and recording the findings of, fire risk assessments (FRAs) in housing premises and parts of housing premises.

This British Standard is applicable to:

1. houses in multiple occupation (HMOs);

2. blocks of flats or maisonettes (both purpose‑built blocks and buildings converted to flats);

3. specialized housing (see 3.1.66);

4. student accommodation falling into any of the above three categories; and

5. those areas that provide access to residential accommodation in mixed‑use buildings.

This British Standard is not applicable to:

1. a private dwelling (single household dwelling);

2. premises used solely for short‑term letting (e.g. of flats) (see 3.1.63), including peer‑to‑peer rented accommodation (see 3.1.53);

3. non‑domestic premises; and

4. residential care homes.

This British Standard is not applicable to premises during the construction phase²⁾, before the building is used as housing, but it is applicable to vacant premises.

The methodology in this British Standard addresses external walls, but does not cover specialist fire risk appraisals of external wall construction and cladding (FRAEWs).

The methodology in this British Standard is intended to determine the preventive and protective measures that are necessary to protect occupants of housing premises and people in the immediate vicinity of the premises. The methodology is not intended to address the safety of firefighters in the event of a fire on the premises. It is not intended to address protection of property (the premises and their contents) or the environment, or protection of a business against interruption.

5 Principles and scope of fire risk assessments

COMMENTARY ON CLAUSE 5

The FRA is a systematic and structured assessment of the fire risk (see Clause 4) in premises for the purpose of expressing its current level, determining the adequacy of existing fire precautions (see 3.1.28) and determining the need for, and nature of, any additional fire precautions. Any such additional fire precautions required are set out in the action plan (see 3.1.2), which forms part of the documented FRA (see Clause 10). The objective of the action plan is to set out measures that will reduce the fire risk to, or maintain it at, a tolerable level (see 3.1.72).

This clause describes the general principles of FRAs, and sets out some specific matters for consideration when determining the scope of an FRA.

1. General principles

   It follows from the definition of fire risk that the FRA involves consideration of relevant fire hazards and the means for their elimination or control, i.e. fire prevention measures. This approach to fire risk assessment tends to parallel that adopted in health and safety risk assessments, whereby the objective of the risk assessment is not limited merely to preventing harm to people as a result of a hazard, but begins with endeavours to eliminate or reduce the hazard itself. Thus, the FRA begins with endeavours to reduce the likelihood of fire.

   The likelihood of fire is rarely reduced to zero. Accordingly, there is normally need for fire protection measures, such as protection of means of escape (see 3.1.49), measures that assist in the use of escape routes (see 3.1.15), means of giving warning of fire, means for fighting fire and structural fire protection. However, these fire protection measures, by definition, only have a bearing on fire safety after fire has occurred and, therefore, fire prevention has failed.

   Where, originally, the premises have been designed on the basis of fire safety engineering, and have been approved under relevant legislation, it is not generally necessary to check this design from first principles in the course of the FRA. It is, however, necessary to verify that features and facilities that form part of the design and fire strategy are being properly maintained and managed. Where it becomes apparent that the design of the building compromises fire safety, it can be appropriate to propose a review of the design.

   It is not expected that, in all FRAs to which this British Standard applies [see item c) below], intrusive investigations of structural fire protection (e.g. involving opening up of the structure or removal of a section of ceiling) will be carried out. However, where doubt exists as to the adequacy of structural fire protection, either through material changes to the building over time, or due to its age and historical nature, it might be necessary to make a recommendation for an in‑depth assessment of the structural fire protection, which might be performed by specialists; the results of this in‑depth assessment can then be incorporated into the FRA.

   Similarly, it is not expected that FRAs will involve testing of active fire protection measures (see 3.1.31 and Clause 15).

   Every FRA needs to give thorough attention to fire safety management and, therefore, to matters such as the fire strategy for the premises, fire procedures [including their dissemination to residents, regardless of whether the evacuation strategy is “stay put” (see 3.1.68) or simultaneous evacuation (see 3.1.64)], training of any staff in the premises, testing and maintenance of fire protection equipment, inspection of means of escape, control over alterations, control of work by contractors, etc. Good fire safety management can also contribute to the prevention of fire by incorporating policies and measures that reduce the likelihood of fire.

   It follows, therefore, that for an FRA to be fully effective, it needs to be carried out on premises that are in use, so that the actual working conditions, practices and procedures can be taken into account. However, there might also be circumstances when an FRA needs to be carried out at other times, e.g. when premises become vacant for any period during the life of the building.

   The fire prevention measures, fire protection measures and components of fire safety management can be treated as variables, according to the fire risk, in order to provide an integrated package of measures that limits fire risk to a tolerable level.

   The structured approach taken in this British Standard is based on nine steps, as detailed in Clause 11 and summarized in Figure 1.

   It is not appropriate for an FRA to justify a decision regarding fire precautions that has already been made without due consideration of risk, or to justify significant departures from universally recognized industry good practice (e.g. the frequency of testing and maintenance of fire protection systems recommended in relevant British Standards).

2. Factors impacting on fire risk

   Factors that impact on fire risk, but which are not variable and are “given” factors for the premises in question, include, but are not limited to, those listed in 12.1.

   Although these factors cannot (or cannot readily) be changed, their effect on fire risk (primarily as a result of their effect on the consequences of a fire) needs to be taken into account in the FRA, so that they can be reflected in the level of fire risk expressed. The level of fire precautions then needs to be proportionate to the level of risk.

   Since the likelihood of fire and the consequences of fire, if it does occur, are largely independent factors (see Clause 4), they need to be considered separately in the FRA (see Figure 2).

   For example, in properly designed, constructed and maintained single‑storey premises with sufficient fire exits and occupants who do not require assistance to escape, a fire might have less serious consequences to occupants (in terms of injury) than in the case of multi‑storey premises with poor compartmentation and more people who require assistance to escape. Conversely, in a high‑rise block of flats with well‑designed escape routes and a good standard of compartmentation, if there is a significant build‑up of combustible materials in the common parts, the consequences to occupants in the event of fire in the common parts could be serious. In each of these examples, poor standards of fire safety management could affect both the likelihood of fire and the consequences of fire.

   Once the level of fire risk is determined, any need for improvements in fire precautions can be identified. It can be determined whether the problem is primarily one of high likelihood of fire, necessitating fire prevention measures in the action plan, or serious consequences in the event of fire, necessitating fire protection measures, or a combination of the two.

   The determination of the likelihood of fire, the consequences of fire, and fire risk, are typically subjective in nature, and not quantified numerically. Numeric methods, including calculation of probabilities and use of fire scenarios (see 3.1.42), are not typically appropriate for housing premises.

3. Types of FRA

   The scope of an FRA needs to take account of the nature of the premises and the existing information available in respect of the structural and other fire protection measures.

   There are, in principle, four different types of FRA that can be carried out in any multi‑occupied housing premises. These are illustrated in Figure 3. They differ in the extent to which the building is inspected, and in the use of intrusive techniques for opening up and sampling construction materials or elements that are not visible.

   

   The fire risk assessor needs to have a clear understanding of the type and scope of FRA that is required so that they can conduct it accordingly. It is the responsibility of the dutyholder to provide this information.

   The four types of FRA are described below.

   1)	Type 1: Common parts only (non‑intrusive) A Type 1 FRA is the basic FRA, and is generally sufficient for most buildings where there is evidence of the integrity of the building. The Type 1 FRA inspection is non‑intrusive and would not involve opening‑up work, such as cutting holes in, or removal of, walls, ceilings, partitions, etc. Evidence of building integrity could be obtained through, for example, visual inspection, previous structural and compartmentation surveys, previous intrusive inspections, or information on the building’s design and construction standards. Where evidence is not available, a Type 1 FRA might not be appropriate. A full and thorough visual inspection of reasonably accessible compartmentation and other passive measures is likely to be necessary in some situations (see 15.7). As well as considering the arrangements for means of escape, etc., the Type 1 FRA includes examination of, at least, a sample of entrance doors and door sets to the dwellings, e.g. flats or bedsits (see 15.3). Where the building has a pitched roof, the inspection extends to the roof voids, unless access to the voids is impractical, in which case this needs to be recorded in the FRA (see 15.7). The inspection also covers, so far as reasonably practicable, the separating construction between the dwellings and the common parts, without any opening up of construction. This includes, for example, inspection of fire stopping within sample locations within service risers. Where there are demountable false ceilings in the common parts, it is appropriate to lift a sample of reasonably accessible false ceiling tiles. In addition, it is normally appropriate to open a sample of service risers, provided that access is practicable at the time of inspection (see 15.7). In a Type 1 FRA, consideration needs to be given to external wall construction, including any cladding or attachments such as balconies (see 15.10). In the case of external wall construction that is of traditional masonry construction (e.g. external walls which comprise either two leaves of masonry or a solid masonry leaf, solid concrete or stone construction), without attachments that are likely to result in serious risk of external fire spread, it is normally reasonable to assume that the fire risk associated with the external walls is acceptable without further investigation, in which case this can be recorded in the FRA. (This does not imply that the fire risk assessor is verifying that external walls conform to the requirements of building regulations that are current at the time of the FRA or were current at the time of construction of the building.) For other types of external wall construction, an FRAEW might be appropriate (see 15.10).
   2)	Type 2: Common parts only (intrusive) The scope and objectives of a Type 2 FRA are generally similar to those of a Type 1 FRA, except that there is additional intrusive inspection, carried out on a sampling basis. This usually necessitates the presence of a contractor for the purpose of opening up construction and making good after the inspection. NOTE 1    Attention is drawn to the Control of Asbestos Regulations 2012 [6]. In order to check the integrity of separating construction, the areas in which intrusive inspection is carried out might sometimes include a sample of dwellings. A Type 2 FRA is usually a one‑off exercise, which is carried out only if there is good reason to suspect serious structural deficiencies that could lead to spread of fire beyond the dwelling of fire origin. The need for a Type 2 FRA is sometimes identified in a Type 1 FRA, but ought not to be recommended as a matter of course.
   3)	Type 3: Common parts and dwellings (non‑intrusive) A Type 3 FRA includes the work involved in a Type 1 FRA, but also considers precautions within the dwellings themselves. This type of FRA considers the provision, arrangements and maintenance of fire precautionary measures within the control of landlords, leaseholders, other dutyholders or occupiers, such as means of escape, fire detection systems and sprinkler or water mist systems, within at least a sample of the dwellings. It also considers any alterations or actions by residents that could compromise the effectiveness of the fire precautions. Measures to prevent fire are not considered unless (e.g. in the case of maintenance of the electrical and heating installations) the measures are within the control of, for example, a dutyholder. A Type 3 FRA can also provide an opportunity for dutyholders, leaseholders and occupiers to be given advice on best practice in the provision of fire precautions, over and above the minimum requirements of legislation (e.g. advice on additional smoke and/or heat alarms beyond the minimum required by the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 [7]). Matters to be considered in a Type 3 FRA could include: integrity of fire‑resisting elements (walls, floors, ceilings) between the dwelling and other dwellings; maximum travel distance from any point within a flat to the flat entrance door; protection of hallways (where relevant); ease of opening of the dwelling entrance door; fire safety of inner rooms (if any); means of escape from upper levels of any maisonettes; electrical and heating installations provided by dutyholders; provision of smoke and/or heat alarms; and provision of sprinkler or water mist systems.
   4)	Type 4: Common parts and dwellings (intrusive) A Type 4 FRA has the same scope of work as a Type 3 FRA, except that there is a degree of intrusive inspection, in both the common parts and the dwellings, carried out on a sampling basis. This usually necessitates the presence of a contractor for the purpose of opening up construction and making good after the inspection. NOTE 2    Attention is drawn to the Control of Asbestos Regulations 2012 [6]. A Type 4 FRA is the most comprehensive FRA, but is only appropriate in unusual circumstances, such as when a new landlord takes over a building 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 dwellings and a fire in a neighbour’s dwelling. As well as considering the safety of residents in the event of a fire in their own dwelling, consideration is given to the potential for fire to spread internally from that dwelling to others. Routes to assess include riser shafts running within the dwellings, bathroom and kitchen extract ducts, drainage pipework and penetrations for other services, such as gas or electricity.

4. FRA scope limitations

   The FRA does not provide any of the following:

   1. a compliance audit;

   2. an access audit relating to access for disabled people;

   3. a method for identifying latent defects in construction or compartmentation (see 3.1.9);

   4. a method for verifying (e.g. through assessment in lieu of testing) the fire resistance of structural elements of the building;

   5. a method for determining (e.g. through assessment in lieu of a structural fire safety engineering analysis) the potential for structural collapse of a building, or part of a building, in the event of fire;

   6. a method for undertaking a fire risk appraisal of external wall construction and cladding (FRAEW);

      NOTE 3    PAS 9980 gives recommendations for undertaking an FRAEW on existing blocks of flats.

   7. a documented fire strategy;

   8. a means for snagging of new construction;

   9. a guide to fire safety; or

   10. a guide to legislation for the dutyholder.