Fire Risk Assessment - Residential Properties
A fire risk assessment is the foundation for the fire safety measures required in a block of flats, house of multiple occupation, hotel or other premises where people sleep.
A suitable and sufficient fire risk assessment carried out by, or on behalf of, the responsible person will help to ensure that the chance of fire occurring in the areas under the control of the responsible person is minimised. It also helps to ensure that, in the event of a fire anywhere in the block, people can, if necessary, use the common parts safely to evacuate the building. The fire risk assessment will also ensure that appropriate managerial arrangements, such as fire procedures and maintenance of fire safety measures, are in place.
A fire risk assessment is required by legislation. Its purpose is to evaluate the risk to people from fire.
It enables the responsible person to determine the necessary fire safety measures required.
It is normally only necessary to consider the common parts to satisfy the FSO.
Where a landlord has concern regarding risk to residents within their flats, the fire risk assessment may extend to the flats themselves.
Intrusive fire risk assessments (involving destructive exposure) will only be necessary where there is justifiable concern regarding structural fire precautions.
A fire risk assessment need not always be carried out by specialists, but where external specialists are used, care should be taken to ensure their competence.
Fire risk assessments should be reviewed regularly and when circumstances change.
Accordingly, to avoid some common misconceptions, the following points should be noted.
A fire risk assessment is not carried out at the design stage of a building.
A fire risk assessment is not a building snagging exercise, carried out just prior to occupation; it can only be completed after the building is in use.
A fire risk assessment need not always be carried out by specialists, such as consultants. Use of this guide might enable the responsible person to carry out their own fire risk assessment, particularly in small, simple blocks of flats.
Normally, fire risk assessments need not involve destructive inspection of the building, such as opening up of construction. However, where practicable, it may be appropriate to lift a sample of accessible false ceiling tiles, or to open a sample of service risers.
Although the scope of a fire risk assessment is limited to the common parts, it is essential that the fire resistance between the flats and the common parts is considered. In particular, it will be necessary to examine at least a sample of flat entrance doors to ensure that they are fire-resisting and self-closing. Care should be taken to look out for other obvious ready routes where fire might spread between the flats and the common parts, such as meter or milk delivery cupboards, windows, and so forth.
A fire risk assessment is not an exercise to identify failings in workmanship and materials at the time a new building is handed over. It is equally not intended to identify all latent defects in existing buildings. It is undoubtedly the case that a fire may reveal hidden shortcomings that could not reasonably be identified by a fire risk assessment.
Simply because the FSO requires that, where necessary, certain fire safety measures are required, it does not mean that such measures are necessary in all cases. For example, the FSO requires that, where necessary, all premises to which the Order applies have adequate fire extinguishers and fire alarm systems. In a purpose-built block of flats, these measures are not normally necessary in the common parts.
It is not sufficient for a fire risk assessment to consider only the measures needed to assist residents to escape from fire. For example, measures to prevent a fire within the common parts must be considered, as must the maintenance of any measures that were required under Building Regulations for the safety of, or use by, the fire and rescue service.
Although the FSO only applies to the common parts, residents within flats are ‘relevant persons’, whose safety from a fire that starts in or spreads to the common parts, must be considered.
Types of fire risk assessment
The scope of a fire risk assessment needs to be relevant to the nature of the premises and the amount known in respect of the structural protection. There are, in principle, four different types of fire risk assessment that can be carried out for a purpose-built block of flats. They differ in the extent to which the building is inspected.
Type 1 – Common parts only (non-destructive)
A Type 1 fire risk assessment is the basic fire risk assessment required for the purpose of satisfying the FSO.
The inspection of the building is non-destructive. But, as well as considering the arrangements for means of escape and so forth, the fire risk assessment includes examination of at least a sample of flat entrance doors. It also considers, so far
as reasonably practicable, the separating construction between the flats and the common parts without any opening up of construction. However, in this Type of fire risk assessment, entry to flats beyond the area of the flat entrance door, is not involved.
Where there are demountable false ceilings in the common parts, it may be appropriate to lift a sample of readily accessible false ceiling tiles. In addition, it will normally be appropriate to open a sample of service risers, provided access is practicable at the time of inspection.
Unless there is reason to expect serious deficiencies in structural fire protection –such as inadequate compartmentation, or poor fire stopping – a Type 1 inspection will normally be sufficient for most blocks of purpose-built flats. Where doubt exists
in relation to these matters, the action plan of a Type 1 fire risk assessment may recommend that one of the other types of fire risk assessment be carried out or that further investigation be carried out by specialists. (However, this should not be a generic recommendation of all Type 1 fire risk assessments; the recommendation should be based on identification of issues that justify reason for doubt.)
Type 2 – Common parts only (destructive)
The scope and objectives of a Type 2 fire risk assessment are generally similar to those of a Type 1 fire risk assessment, except that there is a degree of destructive inspection, carried out on a sampling basis. This will usually necessitate the presence of a contractor for the purpose of opening up construction and making good after the inspection.
In order to check the integrity of separating construction, the areas in which destructive inspection is carried out might sometimes include a sample of flats. However, because of the nature of the work, this can often only be carried out in vacant flats.
A Type 2 fire risk assessment 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 flat of fire origin. The age of the block alone is not generally sufficient to warrant a Type 2 inspection. The need for a Type 2 fire risk assessment may sometimes be identified in a Type 1 fire risk assessment, but should not simply be recommended as a matter of course.
Type 3 – Common parts and flats (non-destructive)
A Type 3 fire risk assessment includes the work involved in a Type 1 fire risk assessment, but goes beyond the scope of the FSO (though not the scope of the Housing Act). This risk assessment considers the arrangements for means of escape and fire detection (ie smoke alarms) within at least a sample of the flats. Within the flats, the inspection is non-destructive, but the fire resistance of doors to rooms is considered.
Measures to prevent fire are not considered unless (eg in the case of maintenance of the electrical and heating installations) the measures are within the control of, for example, the landlord.
A Type 3 fire risk assessment may sometimes be appropriate for rented flats if there is reason to suspect serious risk to residents in the event of a fire in their flats. (This might be, for example, because of the age of the block or reason for suspicion of widespread, unauthorised material alterations). This type of fire risk assessment will not be possible in the case of long leasehold flats, as there is normally no right of access for freeholders.
Type 4 – Common parts and flats (destructive)
A Type 4 fire risk assessment has the same scope of work as a Type 3 fire risk assessment, except that there is a degree of destructive inspection, in both the common parts and the flats, carried out on a sampling basis. This will usually necessitate the presence of a contractor for the purpose of opening up construction and making good after the inspection. However, the nature of the work is such that, often, destructive inspection within flats can only be carried out in those that are vacant.
This is the most comprehensive fire risk assessment, but will only be appropriate in limited circumstances – such as when a new landlord takes over a block of flats 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 flats and a fire in neighbours’ flats.
Note: Before destructive inspection is to be carried out, the risk of disturbing asbestos should be considered (eg by examination of the asbestos register).
Links to useful documentation
Fire Safety in Purpose Built Block of Flats