Fire Safety in Multi-Occupancy Buildings

Fire Safety in Multi-Occupancy Buildings | Fletcher Risk Management
Fire Safety Guidance

When a building is shared between more than one organisation, fire safety responsibilities do not divide themselves neatly along tenancy boundaries. Understanding who is responsible for what — and making sure those responsibilities are properly coordinated — is one of the more demanding aspects of fire safety management in commercial property.

Across Chester, the wider North West, and into North Wales, a significant proportion of commercial property is occupied by more than one business. Managed office buildings, converted town centre premises, business parks with shared facilities, and mixed-use developments all present the same fundamental challenge: multiple organisations operating under the same roof, each with their own employees, visitors, and working practices, but sharing escape routes, alarm systems, fire doors, and common areas. The Regulatory Reform (Fire Safety) Order 2005 applies to all of them, and it places clear duties on every responsible person in the building — not only the landlord or managing agent, but each occupying organisation as well.

Getting fire safety right in these buildings requires more than each tenant carrying out their own fire risk assessment in isolation. It requires coordination, communication, and a shared understanding of the building's overall evacuation strategy. Where that coordination breaks down, the consequences can be serious — and the enforcing authority, Cheshire Fire and Rescue Service or North Wales Fire and Rescue Service depending on location, will hold each responsible person to account for their own part of that failure.

Who is the responsible person in a multi-occupancy building?


The FSO defines the responsible person as the employer in relation to a workplace, or the person who has control of the premises to any extent. In a multi-occupancy building, this means there will typically be more than one responsible person — each occupying employer is the responsible person for their own demise, while the building owner or managing agent is the responsible person for the common parts, including shared corridors, stairwells, lobbies, and any plant rooms or service areas.

This distinction matters in practice. A tenant on the second floor of an office building is responsible for the fire risk assessment covering their own space and the safety of their employees and visitors within it. The managing agent or freeholder is responsible for ensuring that the common escape routes are adequately protected, that the building's fire detection and alarm system covers all areas, and that the overall evacuation strategy is coherent. Neither party can discharge their duties by pointing to the other's responsibilities — the obligations are concurrent, not alternative.

Managing agents working across commercial portfolios in Chester and Cheshire will find more specific guidance on their role on our managing agents page. For agents overseeing buildings with multiple tenants, the coordination function is often the most demanding part of the fire safety obligation.

Legal requirementSince the Fire Safety Act 2021 and subsequent changes brought in under section 156 of the Building Safety Act 2022, all responsible persons are legally required to take reasonable steps to identify other responsible persons sharing the same premises, make themselves known to those persons, and cooperate in the management of fire safety across the building as a whole.

The duty to cooperate and coordinate


The FSO has always required responsible persons sharing a building to cooperate with one another, but the Building Safety Act 2022 made this duty more explicit. Each responsible person must now take reasonable steps to ascertain the existence of other responsible persons in the same building, identify themselves to those persons, and share relevant fire safety information with them. Where a responsible person leaves the premises — because a tenant vacates, or a managing agent changes — they must pass on all relevant fire safety information to whoever takes over, so that the chain of knowledge about the building's fire safety history is maintained.

In practical terms, this means that tenants in a shared building should know who the responsible person is for the common parts, understand the building's overall evacuation strategy, and ensure that their own emergency procedures are consistent with it. It also means that managing agents and building owners cannot treat fire safety as purely an administrative function — they need to be actively engaged with their tenants' arrangements, particularly where those arrangements affect shared escape routes or the building's alarm system.

The requirement to record fire safety arrangements also applies to every responsible person, regardless of the size of the organisation. A small business occupying a single floor of a managed office building in Chester city centre is still required to document its fire risk assessment findings, record its emergency procedures, and keep that documentation up to date. The days when only larger organisations with five or more employees needed to record their findings are gone.

Fire risk assessments: what each party needs to cover


A fire risk assessment for a tenant in a multi-occupancy building should cover the specific risks arising from that tenant's occupation — the nature of the work being carried out, the materials present, the number and characteristics of the people in the space, and the adequacy of the means of escape available from their demise to a place of safety. It should also address how the tenant's evacuation arrangements interact with the building's overall strategy, and whether there are any conflicts or gaps.

The responsible person for the common parts should ensure that the building-level fire risk assessment covers all shared areas and the overall fire safety management of the building. Where the building contains tenants with particularly high-risk operations, or where the mix of occupiers changes frequently, the building-level assessment may need to be reviewed more regularly than the standard annual cycle would suggest.

One area that often causes confusion in multi-occupancy buildings is the fire alarm system. In many managed office buildings, the fire detection and alarm system covers the whole building, is monitored centrally, and is maintained by the managing agent's contractor. Individual tenants may have no direct relationship with the alarm system but rely on it completely for early warning of a fire. It is important that the tenant's fire risk assessment acknowledges this dependency and that the managing agent's maintenance records confirm the system is functioning correctly throughout all occupied areas. Our guidance on fire safety generally covers alarm grades and categories in more detail.

Evacuation strategies in shared buildings


Agreeing and maintaining a coherent evacuation strategy across a multi-occupancy building is more complicated than it might appear. Different tenants will have different numbers of staff, different working hours, different visitor volumes, and potentially different physical layouts. Some may operate shift patterns that mean the building is occupied at unusual hours; others may host large meetings or events that significantly increase the number of people in the building at any one time.

The evacuation strategy for the building as a whole must account for all of these variables. Where a simultaneous evacuation is the strategy — as is the case in most low-rise commercial buildings — every responsible person needs to ensure their staff know the procedure, know the escape routes, and can carry it out effectively. Where the building uses a phased or progressive evacuation strategy, typically found in taller or more complex buildings, each tenant's fire warden arrangements need to be integrated with the overall phasing plan.

Fire safety training for staff is a legal requirement under the FSO, and in a multi-occupancy building it takes on an added dimension. Employees need to understand not just their own organisation's procedures but the building-wide evacuation plan — including where the assembly point is, who the fire wardens are in the common areas, and what to do if they encounter an obstruction or a problem with a shared escape route. For buildings in Chester, Warrington, or across the Wirral where multiple businesses may be operating across several floors, this coordination between tenants is often the weakest link in the chain.

Assembly pointsIn shared buildings, the assembly point is a building-level decision, not a tenant-level one. Every occupying organisation needs to know where it is, ensure their staff know it, and confirm it is workable for the full population of the building — not just their own employees. A mismatch between tenant evacuation plans and the building's designated assembly point is a common finding in fire risk assessments of multi-occupancy premises.

Fire doors in common areas


Fire doors in the common parts of a multi-occupancy building are the responsibility of whoever has control of those areas — typically the managing agent or landlord. They form a critical part of the means of escape for every occupier in the building, and their condition directly affects the safety of all tenants and their visitors, not just the occupier whose demise they protect.

The Fire Safety (England) Regulations 2022 introduced specific requirements for fire door inspections in multi-occupied residential buildings, and while those requirements apply primarily to the residential sector, they reflect a broader principle that applies across all multi-occupancy buildings: fire doors must be checked regularly, maintained to a standard that ensures they will perform as intended in a fire, and replaced when they no longer meet that standard. Our fire door inspection service is available to building owners and managing agents across Chester, Cheshire, the Wirral, and North Wales, and covers both common area doors and those within individual demises.

Tenants should be aware that the fire doors within their own demise — including any doors that open onto shared corridors — are part of their own fire safety responsibilities. A tenant who props open a fire door between their office and a shared escape corridor, or who installs a replacement door without checking its fire rating, may be creating a risk not just for their own staff but for every other occupier in the building.

Buildings across Chester, the North West, and North Wales


The practical challenges of multi-occupancy fire safety are visible across the region. Chester's historic city centre contains a large number of converted buildings — former banks, Victorian commercial premises, and listed buildings — that now house multiple businesses across several floors, often with shared staircases, narrow escape routes, and alarm systems that were retrofitted rather than designed from the outset. Buildings of this kind require careful fire risk assessment work that takes account of the building's specific construction and layout, rather than applying generic templates.

Across the Wirral, the North West more broadly, and into North Wales, business parks and managed office developments present a different set of challenges — typically more modern construction, but with common facility management arrangements, shared loading bays and car parks used as assembly points, and tenant mixes that can change frequently as businesses grow, contract, or relocate. In these settings, the managing agent's oversight role is particularly important, and the quality of their fire safety management directly affects every organisation in the building.

We carry out fire risk assessments across all of these building types throughout our coverage area, and we are familiar with the specific characteristics of the commercial building stock across Chester, Cheshire, Merseyside, the Wirral, Warrington, and into North Wales. Where a building presents particular complexity — whether because of its age, its mix of tenants, or the nature of the businesses operating within it — we work with both building owners and individual occupiers to ensure that the fire risk assessments at each level of the building's management are coherent and complete.

What changes when a tenant moves in or out


Tenant turnover is one of the moments when multi-occupancy fire safety is most likely to go wrong. When a new occupier moves into a building, they bring with them new risks, new numbers of people, potentially new materials or processes, and a team of staff who are unfamiliar with the building's layout and evacuation procedures. The responsible person for the common parts — and the incoming tenant themselves — both have obligations to manage this transition.

The outgoing tenant is required to pass on relevant fire safety information to whoever takes over their space. The managing agent should ensure that the building-level fire risk assessment is reviewed in light of the new occupier's activities, and that any changes to the building's fire safety arrangements — such as alterations to the layout, new partitioning, or changes to the alarm zoning — are properly assessed before the new tenant takes occupation. The incoming tenant should carry out their own fire risk assessment promptly, brief their staff on the building's evacuation procedures, and identify their fire wardens.

For office and commercial premises where tenant churn is frequent, building owners and managing agents may find it worthwhile to establish a formal induction process for incoming tenants that covers fire safety alongside the usual lease administration — ensuring that every new occupier understands their obligations from day one, and that the building's overall fire safety picture remains coherent through the inevitable changes in occupancy.

A checklist for responsible persons in shared buildings


The following summarises the key areas that responsible persons in multi-occupancy commercial buildings — whether building owners, managing agents, or individual tenants — should have in order.

Identify

Take reasonable steps to identify all other responsible persons in the building, make yourself known to them, and record each party's name, UK address, and the extent of their responsibilities under the FSO.

Assess

Carry out a suitable and sufficient fire risk assessment covering your own demise, ensure it addresses the interaction with the building's shared areas, and review it regularly or when circumstances change.

Record

Document all findings from the fire risk assessment and record your fire safety arrangements in writing. This is a legal requirement for all responsible persons, regardless of the size of the organisation.

Coordinate

Share your evacuation procedures with the other responsible persons in the building and satisfy yourself that they are consistent with the building's overall strategy. Agree a shared assembly point and ensure all staff know it.

Train

Ensure all staff receive adequate fire safety training, including on the building's evacuation procedures. Appoint and train fire wardens appropriate to the size and nature of your occupation.

Inspect

Ensure fire doors within your demise are inspected and maintained. Managing agents should ensure that common area fire doors are subject to regular inspection and that any defects are remedied promptly.

Review

Revisit your fire risk assessment and procedures when a new tenant moves in, when there are changes to the building's layout or systems, or when your own operation changes in ways that affect fire risk.

For managing agents overseeing buildings across Chester, Cheshire, the Wirral, and North Wales, we are well placed to assist with both building-level fire risk assessments and with the coordination work that multi-occupancy buildings require. We also work directly with individual tenants and occupying businesses who need their own assessment carried out, whether as a new occupier, as part of an annual review, or following a change in their operations. Further information on the sectors we work in — including offices and commercial premises, warehouses and industrial premises, and hotels — is available on our sector pages.

Fire safety across shared buildings

Whether you manage a multi-occupancy building or occupy part of one, Fletcher Risk Management can help you understand your fire safety obligations and put the right arrangements in place. We cover Chester, Cheshire, the Wirral, Merseyside, Warrington, and North Wales.

This article is intended as general guidance on fire safety obligations in multi-occupancy commercial buildings under the Regulatory Reform (Fire Safety) Order 2005 and associated legislation. It does not constitute legal advice. Fire safety requirements vary according to building type, height, use, and occupancy, and responsible persons should seek professional advice specific to their circumstances. Fletcher Risk Management Ltd is a fire safety consultancy, not a legal practice.
Next
Next

Mold - Fire Safety in Focus