Refreshing fire risk assessment

A changing focus

Distinct phases exist in construction, perhaps best exemplified by the RIBA Plan of Work, which provides the most well-known segregation stages, to which we have added further separations and steps. The Building Safety Act 2022, with its principal responsibilities and progressive gateways, now exists and we can foresee further change to implement recommendations from the Grenfell Inquiry Phase 2 report.

Already recommendations from the Inquiry Phase 1 report have had an impact on fire risk assessment, primarily on external walls and flat entrance doors, and we now read the future should include mandating fire risk assessor competence. So, just as in any building’s lifecycle of change, we can see the changing perception of risk from fire alongside any physical adaptations.

The response so far to this change in perception has been remarkable if unrecorded. Fire risk assessment has become even more contextualised towards the protection of life, leaving property protection and asset loss in a secondary position, and terms like ‘proportionality’ have entered the built environment playbook as ‘value engineering’ fades away.

External walls, once regarded as of little importance, are now seen as a substantial threat because of the risk of breaching compartmentation resulting in uncontrolled fire spread. The risk of harm presented by fire to people is heightened with clear concerns around personal vulnerabilities, suggesting both prioritisation of escape rather than shelter practices and better reflection on a person’s individual circumstances. The workplace and residence now feel closer allies when deciding upon the adoption of specific risk mitigation fire safety measures.

In this environment fire risk assessment inevitably finds its early foundations need revision. The purposeful move nearly two decades ago, as part of what was then ‘removal of red tape’ by deregulation, laid those foundations through ‘reforming legislation’ (Fire Safety Order¹) and, rising from that legal base, guidance (as opposed to regulation) soon emerged on the process² and application of risk assessment³. This also provided an outline of competence requirements4.

Since then the legal amendments5, which may appear to have been modest, have had far reaching effects, and will impact the example building - the WRaP (see pp.2-3). External walls (including balconies) and doors between domestic premises and common parts are now clearly in scope’, and Article 50 guidance has had its status raised and responsibilities extended6. In short, the amended FSO has been elevated as a statutory vehicle.

In this period responsible industry, with its commercial, development, and public interests, has continuously reviewed fire risk assessment competence and capacity, prominently arguing and producing guidance to reinforce a conviction that third-party assurance was a public safeguard, whilst both enhancing and improving competence requirements.

Given all this background, when coming up-to-date the expectation might be that all is well organised. Unfortunately, that is not quite the case, not least because of the drive to improve competence remains and is set to push the pendulum from deregulation in the direction of essentially more regulatory control.

Whilst we must await the government’s response to the Grenfell Inquiry Phase 2 report in Spring 2025, any such regulation suggests a more determined move towards a ‘regulated profession’ for fire risk assessors. A move that requires competence to be measured by conformity to recognised assessment standards – simply put, competence based upon ISO and British Standards. Once instituted effectively there will then exist both competence requirements for the fire risk assessor and defined practices; the latter provided by application of the PAS 79 and PAS 9980 codes.

While this makes good sense there are however a few hurdles, starting first with the role of the fire risk assessor. Even 20 years after the FSO, many believe demarcation around the actual task still remains less explicit than is required. Fire engineer and fire risk assessor are both titles in common use, are often confused with each other, and are often misused.

So let us be clear in the context of buildings as premises in the scope of the FSO, as is true in the case of the WRaP, the requirement is to assess the general fire precautions, meaning those precautions really need to exist. Therefore, a fire strategy and the design, selection, installation, and commissioning of any fire safety measures should have already happened. This situation can easily confuse, after all a workplace can be a building under construction, meaning it is still having its passive and active fire protection systems installed, as work in progress.

Underpinning competency

Understanding the fire risk assessor role is key to defining the competence required. The role defines the skills, knowledge, experience, and behaviour (SKEB) required, which in turn are essential in setting out the competence conformity criteria, regardless of whether that’s for a future-mandated role or to present qualifications that indicate a competent professional. There is already industry guidance8 outlining and offering insight to those SKEB requirements and, with the new British Standard BS 8674? in preparation, there will be a recognised national competence standard.

Although the ultimate test always lies with the law courts, competence criteria should reassure the public that competent work is being done. With its direct relationship to operating within an acceptable public and private culture, behaviour is a critical post-Grenfell component. Rightly it is a requirement for every person, in any role working in construction, to seek to protect the safety of all building users by performing to and within their personal limits of competence.

Going forward it should now be apparent that what was once an accepted position needs improvement. However, calling for a competence standard that recognises a new operational landscape, and one which might be set as the cornerstone of a more regulated profession, has challenges – an existing workforce and its practices cannot change immediately. Industry already has standards and practices, some as mentioned started more than a decade ago. Many fire risk assessors consider themselves competent, some have qualifications or are third-party certified, whilst many others are proficient and experienced. Undertaking fire risk assessments cannot just stop and everyone change direction in an instant; a sensible transition is necessary.

Returning to legislative changes, provision in Section 156(4) of the Building Safety Act 2022 (yet to be enacted) amends the FSO by requiring the Responsible Person to not appoint an assistant to help make or review a fire risk assessment unless that person is competent. To be regarded as competent that person has to have “sufficient training and experience or knowledge and other qualities”. That said it is acknowledged that despite past efforts the numbers of assessors available who can ‘demonstrate’ competence is insufficient to satisfy the forthcoming legislative change.

As part of the response to improve competence in the built environment, the British Standards Institute established in 2020 a strategy group to guide a specialised work programme. It quickly developed a framework standard with standards for principal roles in the building safety regulatory regime. That BSI process now has a formal committee structure, CPB/1 Competence in the Built Environment, under which BS 8674 the competence framework for individual fire risk assessors, is one standard being developed for release in early 2025.

Within BS 8674, the competency criteria is organised at three levels. This will support both a professional career pathway and tailored SKEB to reflect the wide range of occupied buildings and workplaces that exist; from small shops to larger public entertainment venues and from low occupancy non-residential workplaces and buildings under construction, to multi-occupied large residential premises and care settings.

All this effort by industry and government is leading to recognition of a robust conformity standard, underpinned by BS 8674, which, when used under a strengthened Article 50 guidance, has implications bordering on a regulatory requirement. Public scrutiny of qualifications and certification would then ensure that a fire risk assessor is suitably competent for the task to be undertaken.

Transitioning the existing workforce, especially those who may be proficient but unable to demonstrate competence, probably through an absence of qualification or certification to the new standard is ongoing. Also underway are efforts to assist a new generation of fire risk assessors joining the profession, by way of trade apprenticeships, with professional bodies helping to continuously refresh knowledge and skills on matters like the recently announced Residential Personal Emergency Evacuation Plans.