Many Responsible Persons treat a fire risk assessment as a document that is completed once and then filed away until someone asks to see it. It is an easy habit to fall into, particularly when the building seems to carry on much as before. The law, however, sees the assessment as a working document that has to stay accurate for as long as the premises are in use.
The short answer is yes, you do need to review your fire risk assessment. The Regulatory Reform (Fire Safety) Order 2005 requires it to be reviewed regularly, and straight away whenever something significant changes. In this post we explain what the law says, the changes that should prompt a review, what a review involves, and when a full new assessment is needed.
What the law says
Article 9 of the Fire Safety Order requires the Responsible Person to review the fire risk assessment regularly, so that it stays up to date. It also requires a review in two particular situations, namely where there is reason to suspect the assessment is no longer valid, and where there has been a significant change in the matters it covers, such as the premises, the fire precautions or the way work is organised. If the review shows that changes to the fire safety arrangements are needed, the Responsible Person must make them.
The Order also requires the assessment to be reviewed before a young person under the age of 18 is employed, so that the particular risks to them are taken into account. This is easy to overlook in businesses that take on apprentices, students or seasonal staff, such as hotels and hospitality venues over the summer and Christmas periods.
Neither the Order nor the government's guidance sets a fixed review period. Instead, the frequency should reflect the risk in the building. Professional codes of practice ask the fire risk assessor to recommend a date for the next review, and in our experience an annual review is a sensible baseline for most premises. Higher-risk buildings, such as care homes, hotels and larger HMOs, often need more frequent attention.
Changes that should prompt a review
A review should not wait for the date in the report if something has changed in the meantime. Common triggers include:
- building work or alterations, such as a new partition in an office, a new teaching block at a school or a mezzanine floor in a warehouse
- a change in how the building is used, such as a church hall let to community groups in the evenings, or a shop that begins opening late
- a change in the people using the building, such as more staff, members of the public, or residents who may need help to escape
- new processes, equipment or storage, such as contractor hot works, a new commercial kitchen, or rechargeable batteries for e-bikes and scooters
- a fire, a near miss or a false alarm that reveals a problem with the fire precautions
- changes to the fire alarm, emergency lighting, fire doors or sprinklers
- a change of Responsible Person, managing agent or key staff, such as the fire wardens
- a visit or letter from the fire and rescue service
- new legislation or guidance that affects your type of premises
Any one of these may mean the assessment no longer describes the building as it is. When that happens, the existing assessment is no longer reliable, however recently it was written.
Batteries are a common blind spotThe growth in e-bikes, e-scooters and battery-powered tools has introduced new fire risks into many workplaces and residential buildings that were assessed before they were common. If charging or storage now happens on your premises, your assessment should be reviewed. Our post on rechargeable battery fire risk in the workplace explains the issues in more detail.
What a review involves
A review is a structured check that the existing assessment still matches the building, and that the fire safety arrangements are working as intended. It will usually cover:
- a walk round the premises to check for changes in layout, use, occupancy and storage
- progress on the action plan from the last assessment, including any actions that are overdue
- the condition of escape routes, fire doors, signs and fire-fighting equipment
- servicing and test records for the fire alarm and emergency lighting
- staff fire safety training records and the results of recent fire drills
- your fire evacuation plan, and any personal emergency evacuation plans for people who need help to escape, including whether staff are trained to use evacuation chairs
The findings, any changes made and the date of the review should all be recorded. In England, Responsible Persons must now record the fire risk assessment in full, and a clear record of each review is the simplest way to show an inspecting officer that the assessment has been kept up to date.
The action plan is part of the assessmentOne of the most common problems enforcing authorities find is an assessment with an action plan that has never been completed. A review is a good opportunity to work through any outstanding actions and record when each one was closed. An assessment that identifies problems but shows no progress in fixing them can work against you if the premises are inspected.
Review or new assessment?
A review checks and updates an existing assessment. A new assessment starts again from the beginning. Where the changes are limited, such as a new member of staff or a minor change to storage, a review and a short update to the existing record will usually be enough. A full new assessment is likely to be needed where the existing one no longer reflects the building in any meaningful way, such as after a major refurbishment, an extension, a change of use, or a long period without any review at all.
A Responsible Person with the right knowledge can carry out a straightforward review themselves, although they should be confident that they understand what they are checking. For more complex premises, or where significant changes have taken place, it is usually better to ask a competent fire risk assessor to carry out the review or a new assessment.
Is your fire risk assessment due for review?
Our ABBE Level 3 and 4 qualified assessors carry out reviews and new fire risk assessments for offices, warehouses, schools, care homes, hotels, churches and residential buildings across the North West, North Wales and the West Midlands. Every report sets out a recommended review date based on the risk in your building. If you would like a review or a new assessment, please get in touch.
Get a quote Fire risk assessmentsThis article provides general guidance only and does not replace a fire risk assessment or professional advice specific to your premises. The Fire Safety Order applies in England and Wales. Other legislation and guidance referred to apply in England unless otherwise stated.