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FEATURE ARTICLE

07 May 2026

Shared spaces, shared safety

As fire safety regulations in the United Kingdom have evolved, particularly in response to landmark tragedies, ongoing inquiries, and new legislative frameworks, so too has the expectation that evacuation strategies be robust, inclusive, and fully aligned for all occupants of a building. Today, with multi-occupancy office towers, hybrid work models, and increasingly complex building systems becoming the norm, there is no room for ambiguity or complacency.  

Evacuation planning in large commercial and corporate buildings can be complex for a variety of reasons, not least a lack of understanding on the part of building managers and tenants about where responsibility for fire safety arrangements lies. Compounding this in large commercial buildings can be the sheer volume of people requiring evacuation from within the building, multiple stakeholders in leased buildings with differing views on risk management, and the age and potential intricacies of the premises.  

Effective fire safety management demands clarity of responsibility, strong legal compliance, and a coordinated approach between building managers or landlords, and individual tenants

Legal grounding

The starting point for understanding evacuation responsibilities in large commercial buildings is the legislative framework underpinning fire safety in the UK. The cornerstone of fire safety law is the Regulatory Reform (Fire Safety) Order 2005, known as the Fire Safety Order (FSO). Alongside legislation, detailed fire safety guidance covering items such as structural fire protection, escape routes, and fire detection systems can be found in Approved Document B, British Standards such as BS 9999, and Approved Document M which covers in more detail the access and evacuation requirements for occupants with additional needs. 

Legislation and guidance documents in the UK are kept under constant review, and amended as necessary. This increased scrutiny is part of a national effort to prevent a repeat of tragedies such as the Grenfell Tower fire, and ensure that commercial buildings remain safe, even as hazards and protection measures evolve.  

Notably, written fire risk assessments for all commercial premises have become mandatory – historically, if there were less than five employees, written records of fire risk assessments were not required. This change strengthens the golden thread of fire safety information a business holds, which is crucial to ensuring the safety of all occupants. 

The FSO clearly states that the Responsible Person must implement suitable fire safety arrangements, conduct fire risk assessments, and ensure the safe evacuation of all relevant persons. Responsibility for this can filter down from the building manager to duty holders who oversee their own tenanted area of a building, but this does not remove the responsibility for the safety of everyone in the building from the building manager.  

Boundaries of responsibility

Effective fire safety management demands clarity of responsibility, strong legal compliance, and a coordinated approach between building managers or landlords, and individual tenants. This is of particular concern in high-rise, multi-occupancy commercial buildings. There are numerous challenges when it comes to perceived ‘shared responsibility’ in these buildings: who specifically is responsible for what measures in the building? 

It is crucial to remember that building managers or owners cannot transfer their legal responsibility for key fire safety measures to tenants. Whilst it may seem obvious that building managers would be responsible for common facilities and areas in a building enjoyed by all tenants (such as fire detection systems, any firefighting or evacuation lifts, the availability and safety of common escape routes and staircases, and the building-wide evacuation plan) friction can arise over responsibility in a number of other areas. 

The evacuation of occupants with additional access requirements is one possible area of contention. It is essential that individual occupants within a building who require support to evacuate are provided with a Personal Emergency Evacuation Plan (PEEP). This could be for a number of reasons, and includes mobility, sensory, or cognitive requirements.  

Whilst tenants are responsible for identifying employees who require a PEEP and implementing this, these cannot be safely designed without collaboration from building managers, and it is not possible for building managers to abdicate responsibility for the evacuation of anyone with additional needs to the tenant who employs them or invites them onto site as a visitor. This is because the building manager is responsible for ensuring that the entire building can support their safe evacuation.  

Solutions to be implemented to aid evacuation, such as evacuation chairs, must integrate with the building’s infrastructure; for example a tenant purchasing an evacuation chair for use on a tight spiral staircase would not be suitable, though this has been observed in older buildings. The use or non-use of evacuation lifts should be directed by the building manager, and not by individual tenants. These are clearly not procedures which can be implemented by a tenant acting on their own, as they feed into the building-wide evacuation strategy. 

Commercial buildings, especially multi-storey or high-rise buildings, must be considered as a single fire safety ecosystem. This means that tenants cannot operate different evacuation strategies, nor can building managers leave the evacuation of each floor to the tenant and assume the duty holder will look after everyone under their jurisdiction.  

As the evacuation strategy will take account of peak occupancy numbers, which will include any potential visitors and contractors as well as staff in the building, the evacuation strategy for the whole building must be set by the building managers to ensure that all relevant persons can safely evacuate. This includes, as mentioned above, any occupants with additional evacuation requirements. An evacuation plan which does not account for the safety of all occupants is considered legally insufficient, and can result in injury or loss of life.  

There are typically two types of evacuation strategy which may be implemented in large commercial buildings: simultaneous evacuation or phased evacuation. Most people are familiar with a simultaneous evacuation, but given the potential high occupancy numbers of large or multi-storey commercial buildings, a phased evacuation strategy may be safer. Phased evacuation strategies ensure that the floor or floors at highest risk from fire evacuate first. Other floors are then evacuated in a priority order. Typically roof spaces and basements, along with the floor that the fire originates on, are evacuated first, as these are the places of highest risk.  

The effectiveness of evacuations in general can be enhanced with regular fire drills, fire training which focusses specifically on the features of the particular building, and the installation of a Public Address Voice Alarm (PAVA) system. PAVA systems can provide live or pre-recorded instructions for occupants, telling them to evacuate or to be on stand-by to evacuate in a phased evacuation building. This significantly improves response time to the fire alarm, reducing both the ‘learned irrelevance’ people show to the sound of a standard siren and the potential panic in a fire scenario, as clear instructions are spoken to occupants, with research showing that people respond more quickly to voiced commands. 

...evacuation planning in large commercial and corporate buildings within the UK requires more than a basic fire drill or a set of instructions pinned to a noticeboard.

The duty holder’s role

Whilst the responsibilities of the building manager have been highlighted, it is also worth noting that the duty holder for each tenancy has particular responsibilities as well. There is often a misconception that because a building manager is required to carry out a fire risk assessment that covers the whole building, and as mentioned, the building-wide evacuation strategy, that this is sufficient and can be relied upon by tenants.  

However, duty holders are required to have fire risk assessments carried out on their tenanted area. They will have more information on staffing patterns and PEEPs than the landlord will, and also potentially sole responsibility for the provision of fire safety arrangements within their tenancy, such as emergency lighting or portable fire extinguishers, and for the servicing of their own equipment, including Portable Appliance Testing and other planned preventative maintenance. Therefore, whilst the landlord’s fire risk assessment covers common areas and building-wide systems, the tenant’s fire risk assessment covers the interior of their leased premises. These documents must complement one another, and cooperation between parties is a legal requirement under Articles 22 and 23 of the FSO. 

It is essential that clear lines of communication are maintained in the event of an evacuation. There could be several parties involved, including fire wardens (either from the building management team or from each tenanted area), facilities or security teams within the building, and emergency services. It is imperative to know and understand the location of refuge and assembly points, who is responsible for assisting tenants with additional needs, and how to prevent panic or bottlenecks in escape routes. This can be achieved through building-wide evacuation drills, and through the use of fire safety training, particularly for fire wardens.  

Whether training is organised by the building manager or by the individual tenant is a decision for an individual premises, but how an evacuation will be carried out and who is in overall control of that process should be agreed upon; all parties should be singing from the same songbook.  

As shown, evacuation planning in large commercial and corporate buildings within the UK requires more than a basic fire drill or a set of instructions pinned to a noticeboard. It demands a coordinated, legally compliant, and inclusive approach that integrates the responsibilities of building managers and tenants, reflects modern regulatory expectations, and prioritises the safety of every occupant. Whilst fire safety is a shared responsibility, the building’s overall evacuation strategy is the landlord’s duty, and an evacuation strategy cannot be implemented on a tenant-by-tenant basis, but must be building-wide, coordinated, and inclusive. On the other hand, tenants cannot solely rely on a fire risk assessment carried out on the common parts of the premises by the building manager, but must ensure a suitable and sufficient fire risk assessment is also carried out on their tenanted area.  

When these principles are understood, applied, and regularly reviewed, commercial buildings are safer, occupants are better protected, and organisations meet the high standards expected of modern UK fire safety practice.

Paul Riley

Article written by
Paul Riley
Founder My Fire Safety

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