The evolving fire safety landscape
Since the Grenfell Tower tragedy in June 2017, the UK fire safety regulatory framework has undergone the most significant reform in a generation. What was once a relatively settled body of law built around the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005) has been substantially supplemented by the Fire Safety Act 2021, the Building Safety Act 2022, and the Fire Safety (England) Regulations 2022. Duty holders — identified in the legislation as "Responsible Persons" — now operate under a regime of higher expectation, higher scrutiny and materially higher penalty.
The Responsible Person and the legislative framework
Under Article 3 of RRO 2005, the Responsible Person is, in broad terms, the employer, owner, occupier or person having control of non-domestic premises. Where there is more than one Responsible Person, each must co-operate and co-ordinate fire safety measures. The duties imposed on the Responsible Person are extensive and include: undertaking a suitable and sufficient fire risk assessment (Article 9); eliminating or reducing risks so far as reasonably practicable (Articles 8–22); providing general fire precautions; appointing competent persons; and recording significant findings.
The Fire Safety Act 2021 clarified that, for multi-occupied residential buildings, the scope of the fire risk assessment extends explicitly to the structure and external walls of the building (including attachments such as cladding and balconies) and to all doors between domestic premises and common parts — closing the ambiguity exposed at Grenfell.
The Fire Safety (England) Regulations 2022, in force from 23 January 2023, impose further duties on Responsible Persons of multi-occupied residential buildings — including the provision of information to residents, monthly lift inspections in high-rise buildings, annual inspections of flat entrance doors in high-rise buildings, and the provision of building information to local Fire and Rescue Services.
The Building Safety Act 2022
The Building Safety Act 2022 (BSA 2022) introduced a new, more stringent regime for Higher-Risk Buildings (HRBs) — broadly, occupied residential buildings of at least 18 metres in height or 7 storeys with at least two residential units. For HRBs, a Principal Accountable Person (PAP) must be identified, building safety cases prepared, and the Building Safety Regulator notified of occurrence events. The Golden Thread of information — a live, digital record of all fire and structural safety information — must be maintained and shared with successive duty holders and residents.
Fire Risk Assessments — PAS 79-1 and PAS 79-2
The methodology for delivering fire risk assessments is set out in PAS 79-1:2020 (non-residential premises) and PAS 79-2:2020 (residential premises). Both documents, published by BSI and the Fire Protection Association, describe a nine-step process that includes identification of fire hazards, evaluation of fire protection measures, assessment of the likelihood and consequence of fire, and the generation of a risk-scored action plan.
Firesurv Group distinguishes between four types of residential fire risk assessment: Type 1 (non-destructive, common parts only — the default baseline); Type 2 (destructive sampling in common parts); Type 3 (non-destructive, common parts and sample flats); and Type 4 (destructive, common parts and sample flats — typically commissioned where there is reason to believe the fire strategy may be compromised).
Fire doors — FDIS, BS 8214 and the UK Fire Doors scheme
Certified fire doors are one of the most heavily tested elements of passive fire protection — and one of the most frequently found to be defective in real-world inspections. Firesurv Group's fire door inspectors operate to BS 8214:2016 — Code of practice for fire door assembly and hold accreditation under the Fire Door Inspection Scheme (FDIS) and the UK Fire Doors scheme. Every doorset is inspected against a structured 30-point checklist covering leaf, frame, gaps, intumescent seals, smoke seals, ironmongery, glazing and signage.
Compartmentation and passive fire protection
Compartmentation surveys are conducted to BS 9991:2015 (residential) and BS 9999:2017 (non-residential) and focus on the integrity of compartment floors, walls and service penetrations. Particular attention is paid to service risers, ceiling voids and cavities — areas where fire-stopping failures are common and where fire and smoke can spread invisibly. Remedial works are specified and overseen by third-party accredited installers operating under FIRAS and equivalent certification schemes.
Detection, alarm and emergency lighting
Fire detection and alarm systems are designed, installed, commissioned and maintained to BS 5839-1:2017 (non-domestic) and BS 5839-6:2019 (domestic), with system category (L1–L5, M, P1/P2) determined by the building use and evacuation strategy. Emergency lighting is specified to BS 5266-1:2016, with annual full-duration testing and monthly function checks logged in the fire log book.
Evacuation strategies and Personal Emergency Evacuation Plans
The default evacuation strategy in purpose-built residential blocks remains "stay put", predicated on the effectiveness of compartmentation. Where compartmentation is compromised, a temporary simultaneous evacuation strategy is implemented, often supported by a common alarm system and a waking watch. Personal Emergency Evacuation Plans (PEEPs) are prepared for residents with mobility or sensory impairments, aligned with the HSE's guidance and BS 9991.
Enforcement and why it matters
Since 2023, penalties for breaches of RRO 2005 include unlimited fines and imprisonment of up to two years. The Sentencing Council's guidelines ensure that large organisations face turnover-linked penalties running into millions of pounds. Beyond enforcement, a well-evidenced fire safety regime protects lives, protects the building fabric, protects resident confidence and protects the Responsible Person's personal liability.