Practical fire safety - existing high rise domestic buildings: guidance - updated March 2021

Chapter 3: Risk Management – Assessing the Risk to Persons

43. This Chapter sets out the purpose, practicalities and a proposed method for undertaking fire safety risk assessments. This will assist those responsible for fire safety to establish whether existing fire safety measures are adequate, or if improvements are required.

44. It is a strong recommendation that those organisations responsible for the management of high rise blocks, carry out an assessment of fire risk in the building, as part of their corporate responsibility. An example fire safety risk assessment template can be found at Annex 2.

45. A fire safety risk assessment is not, however, legally required under Part 3 of the Fire (Scotland) Act 2005, for the common areas of domestic premises.

Key points

• The purpose of assessing risk is to evaluate the risk to people from fire and determine appropriate fire safety measures.
• The assessment of risk will normally only consider the common areas and limited, specified parts of flats only.
• Concerns regarding risk to individual residents in their own flat should be referred to the SFRS for a Home Safety Visit.
• Fire spread potential on the external facade and roof of the building should be considered.
• Intrusive checks (involving exposure of construction) will only be necessary where there is justifiable concern regarding structural fire precautions.
• Risk assessors must be competent. Where external specialists are chosen, certification or registration schemes can provide some assurance.
• The findings of risk assessments need to be actioned.
• Fire safety risk assessments should be reviewed regularly, when circumstances change or after a fire or near miss.

Scope of Fire Safety Risk Assessment

46. Fire risk is a combination of the likelihood of fire occurring and the consequences to residents and others who may be affected by a fire.

47. A fire safety risk assessment involves an organised and methodical look at the premises, the potential for a fire to occur and the harm it could cause to people. The existing fire safety measures are evaluated to establish whether they are adequate or if more requires to be done. Fire safety measures include not just physical measures, but also standards of management.

48. It is a principle in fire safety risk assessments, that measures to address shortcomings in fire safety should be proportionate to the risk. The cost, practicality and benefit gained are all taken into account.

49. Fire safety risk assessment is concerned with the building and common areas. It does not include an assessment to protect residents from a fire starting in their own flat. Some physical fire safety measures in flats can, however, impact on the safety of the building, for example:

• Flat front doors are normally important to the safety of the common areas in the event of a fire in a flat.
• Reliance was sometimes previously placed on fire doors inside flats to protect not only the internal hallway, but also the common areas.
• Ventilation systems i.e. common kitchen or bathroom extract arrangements can be a route for fire-spread between flats.
• Suppression systems will normally contain a fire within a flat.

Extent of fire safety risk assessment

50. There should be a specific fire safety risk assessment of the premises. A generic risk assessment will not be appropriate.

51. A fire safety risk assessment will cover:

• The common escape routes and other fire safety measures.
• An examination of a sample of flat entrance doors.
• The separating construction between the flats and the common area, so far as reasonably practicable.
• The potential for spread of fire on the external envelope of the building.

52. Normally, a sample of service risers should be opened up to check there are measures to prevent vertical fire spread. Where there are demountable false ceilings in the common areas, it may be appropriate to lift a sample of ceiling tiles to check fire stopping where services or pipes pass through walls/floors.

53. Fire safety risk assessment does not routinely involve opening up construction. However, a degree of intrusive inspection might be carried out on a sample basis if serious issues in structural fire protection are suspected, such as inadequate fire separation or poor fire stopping. This is usually a one-off exercise which requires a contractor to open up construction and make good after the inspection.

54. Intrusive inspection within flats is best carried out in those that are vacant. The risk of disturbing asbestos should be considered before an intrusive inspection is carried out.

Competence of fire risk assessors

55. There is no requirement for a fire safety risk assessment to be carried out by a specialist. The building owners or management should decide whether to use external specialists to carry out a risk assessment, taking into considering whether they, or their employees, have the capability to assess fire risk. If they do not have sufficient resources or skills, they can arrange for a suitably qualified person or company to carry out an assessment.

56. It is important to know that an external fire risk assessor is competent to carry out an assessment. Judging the competence of companies and people that advertise as fire risk assessors can be difficult. The fact that a person or company is operating in the fire sector or that someone has previous fire service experience, does not mean that they are a fire safety specialist.

57. Using registered or third-party certificated persons or third-party certificated firms to carry out fire safety risk assessments is one way to establish competence. The Scottish Government and the SFRS recommend selecting an assessor or company that is third party certificated by a United Kingdom Accreditation Service (UKAS) accredited Certification Body or an assessor registered by a Professional Registration Scheme. SFRS maintains a list of UKAS and other recommended schemes on its website. SFRS has not assessed and does not endorse any individuals or companies participating in these schemes. Assessor participation in these schemes can offer a degree of assurance that the assessor (individual or company) has met the professional requirements.

58. High rise domestic buildings are different from commercial premises, such as offices and shops. In selecting a fire risk assessor, their competence in the principles of fire safety in high rise domestic buildings should be checked.

59. When commissioning a risk assessment from an external consultant the following should be specified:

• The extent of the fire safety risk assessment required.
• The style and format required for the report.
• The improvement plan will show priorities and timescales.
• The report should differentiate between recommendations that are important to safety and those that are not essential and are a matter of good practice.

60. The conclusions from a risk assessment should be supported by reasoned judgement. The following types of conclusion from a fire risk assessor should be challenged:

• Generic recommendations that are not specific to the premises.
• Attempts to transfer risk away from the risk assessor.
• Decisions that appear to be precautionary and to be risk-averse.

Methodology for Assessing Fire Risk

61. Below is guidance on one approach to fire safety risk assessment (Figure 1). There is no requirement for a particular style or format for an assessment or recording the findings. There are other equally acceptable approaches and formats.

Step 1: Obtain information

62. The following information will be relevant for fire risk and control measures:

• The number of floors and the approximate area of each floor.
• Ancillary uses of the building, such as commercial, community activities, etc.
• The number and profile of the residents, including physical, social and known lifestyle factors relevant to fire risk.
• The presence of staff such as a caretaker or concierge.
• Previous history of fires in the block.
• The result of any previous examination of external cladding.
• How fire safety in the building is managed.
• The procedures for residents to follow in the event of fire.
• Testing and maintenance of fire safety systems and equipment.
• Arrangements for routine inspections of the building.

Step 2: Identify potential causes of fire

63. For a fire to start, three components are needed: a source of ignition; fuel; and oxygen. If any component is missing, a fire cannot start. Taking steps to avoid the three coming together will reduce the chance of a fire. Reducing the quantity of oxygen (smothering) or fuel (starvation) may restrict a fire's development.

64. The premises should be examined to identify potential ignition sources and materials that might fuel a fire and the circumstances where a fire could start.

65. The potential for a fire to occur in a flat should be considered as assessors need to consider how a fire in a flat will impact on the safety of others in the building. Control of causes of fire within the flats is normally under the control of the residents and is outwith the scope of the assessment, other than where matters are under the control of the landlord.

66. The potential causes of fire and measures to eliminate or reduce the likelihood of each cause should be considered:

• Fire raising.
• Electrical faults (in fixed wiring and any equipment provided).
• Smoking.
• Use of portable heaters.
• Contractors' activities.
• Heating installations.
• Lightning.
• Housekeeping.

Step 3 Evaluate the risk

67. The risk in the premises should be evaluated and a judgement made on the adequacy of fire safety measures. The two components of risk should be considered: the likelihood that a fire may occur; and the potential for a fire to cause death or injury.

68. Having identified potential causes of fire, consider the chances of a fire occurring. The consequences of a fire and extent of the risk to people should also be considered. In evaluating the risk, it is necessary to consider different situations and possible scenarios such as:

• The potential for fire to affect escape routes.
• Fire or smoke spread through a building via routes such as vertical shafts, service ducts, service penetrations, ventilation systems, cavities, voids and open doors.
• Fire and smoke affecting the behaviour of occupants.
• Fire and smoke spread into the premises from exterior fires.

69. If there have been any previous fires in the premises, considering the circumstances and lessons learned may assist with evaluating risk.

70. The principal fire safety measures to consider are:

• The means of escape from fire, with consideration to;
• The fire resistance between flats and the common areas.
• Flat entrance doors, which should be fire-resisting and self-closing.
• Protection of stairways from fire in adjacent areas.
• Travel distance from flat entrance doors to the nearest stairway or final exit.
• Smoke control within the common areas.
• Emergency escape lighting.
• Fire escape route signs.
• Fire separation, particularly the enclosure of flats within fire-resisting construction.
• Fire suppression installations provided.
• Rising fire mains and firefighters lifts.

Step 4 Decide if existing fire safety measures are adequate

71. A judgement needs to be made to determine whether the fire safety measures and fire safety arrangements are adequate or if more needs to be done to safeguard people. The level of fire safety measures in premises should be proportionate to the level of risk posed to the safety of people and will therefore vary between premises (see Chapter 5 for information). There should be verified maintenance of fire safety measures (see Chapter 6 for information).

72. Measures to assist SFRS, such as rising fire mains and firefighters lifts will normally have been required under Building Regulations at the time of construction. Maintenance is a requirement under the Fire Safety (Scotland) Regulations 2006.

Step 5: Formulate an improvement plan

73. The outcome of the risk assessment needs to be acted upon. The fire safety measures and arrangements need to be put in place to control risk in practice.

74. An improvement plan for fire safety measures considered necessary should be produced. The improvement plan should set out the physical fire safety and managerial measures that are necessary to ensure that fire risk is maintained at, or reduced to, an acceptable level. The actions should be reasonably practicable, taking cost, effort and risk into account. These should be prioritised and have timescales for the completion of the action so that the appropriate effort and urgency is clear. Where the required measures are relatively minor and can be implemented in a short time this is not required.

75. If it is considered that the fire risk and existing fire safety measures are such that no improvements are necessary, this should be recorded within the findings of the fire safety risk assessment.

76. Where improvements involve building work, the work should be done in accordance with building regulation procedures. The improvement plan should also include specific measures and precautions that need to be taken during upgrade work.

Step 6 Record the findings

77. The significant findings from the fire safety risk assessment, and any action taken, or to be taken, should be recorded and retained. There is no specified format for this, but the attached fire safety risk assessment is provided as a useful template.

78. A copy of any completed fire safety risk assessments should be available on request to residents.

Step 7: Review

A fire safety risk assessment should be reviewed regularly with a date set at the previous assessment (see below). It should also be reviewed in instances where:

• Material alterations take place (where changes are proposed, the consequence to fire safety in the premises should be considered before the change is introduced).
• There is a significant change in the matters that were taken into account in the risk assessment.
• There is a reason to suspect that the original assessment of risk is no longer valid.
• There was a fire or near miss

79. The Review of a fire safety risk assessment is not necessarily a repeat of the previous entire fire safety risk assessment process. Where a thorough fire safety risk assessment has been carried out, subsequently a shorter review exercise might be carried out regularly and with an in depth fire safety risk assessment completed less frequently.

80. As a general guide an annual review is appropriate, with a new fire safety risk assessment every three years.

81. There is benefit if reviews are carried out by suitably trained in-house staff, as the review primarily looks at progress of the improvement plan and identification of changes. This process can help reinforce staff ownership of fire safety management and assist in the development of relevant knowledge and fire safety culture.