Practical fire safety for existing specialised housing and similar premises: guidance

Chapter 3: Risk Management – Assessing Premises Based Fire Risk 

Key Points

• The purpose of assessing risk is to evaluate the risk to people in the building from fire and determine appropriate fire safety measures.
• The assessment will normally only consider the common areas and limited, specified parts of flats only.
• Concerns regarding risk to individual residents within their own accommodation should be followed up with a person-centred fire safety risk assessment (see Part 1 of the Guidance).
• 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 fire safety risk assessments need to be actioned.
• The assessments should be reviewed regularly and when circumstances change or after a fire or near miss.
• The premises based fire safety risk assessment is a legal requirement for premises which fall within the scope of fire safety legislation (see Part 4 of the Guidance).

Introduction

127. 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.

128. A premises based 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.

1289. Despite being referred to as “premises based”, the focus of the premises based risk assessment is still life safety:  property protection and business continuity are outside the scope of this Guidance.  It is a more technical process than the person-centred approach, and requires an understanding of the application of fire safety principles to the built environment.  

130. The scope of the premises based risk assessment is far broader than a person-centred assessment, going beyond a single individual and unit of accommodation.  It does not consider the specific characteristics of every vulnerable resident, other than possibly in very small supported housing premises (the number of residents in a sheltered or very sheltered complex would make this impracticable).  It should, however, consider the generic physical and cognitive characteristics of the residents.  

131. There is an overlap between the person-centred and premises based approaches, particularly where measures provided within private accommodation impact on others elsewhere in the building. Examples include:

• Flat entrance doors protect the shared common areas outside the flats from a fire inside a flat.
• Similarly, reliance was sometimes previously placed on fire doors inside flats to protect not only the flat’s internal hallway, but also the shared common areas outside the flats.
• 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/room, thereby protecting both the flat and the rest of the building from firespread.

132. The premises based fire safety risk assessment should confirm there are arrangements for carrying out person-centred risk assessments (which ensures those at greatest risk are adequately protected in their own private accommodation).

133. Where fire safety legislation applies (see Part 4 of the Guidance), it is a legal requirement to carry out this type of fire safety risk assessment and to act on its findings.  If individual person-centred risk assessments are not undertaken, the premises-based risk assessment should ensure it considers the need of persons who are identified as being especially at risk from fire.  Personal Emergency Evacuation Plans (PEEPs) may also be necessary.  

134. Where fire safety law does not apply, it is recommended that those responsible for the premises carry out an assessment of fire risk in the building, as part of their corporate responsibility.

135. As with the person-centred approach, measures to address shortcomings in fire safety should be proportionate to the risk.  The cost, practicality and benefit gained are all taken into account. If justified by risk, it is possible for a standard higher than that required by Building Regulations to be necessary.

Extent of Fire Safety Risk Assessments

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

137. A fire safety risk assessment will cover:

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

138. The assessment will focus mainly on the common areas.  It is unlikely to include a detailed consideration of risk in residents’ private accommodation. It should take account of any features or measures in private accommodation which may have an impact on the safety of the building as a whole.  This could include servicing/maintenance of gas/electricity supplies; provision of automatic detection systems; potential breaches in fire separation.

139. Where there are demountable false ceilings in the common areas, a sample of ceiling tiles should be lifted to check fire stopping where services or pipes pass through walls/floors. A sample of service risers should be checked for measures to stop vertical fire spread.  An inspection of roof voids should also be carried out to ensure appropriate barriers against fire spread are provided.

140. 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. Before starting work, the risk of disturbing asbestos should be considered.

141. Intrusive inspection in private accommodation is best carried out in those that are vacant. Effective fire separation between individual flats, and between flats and common areas, is essential for a “stay put” policy to be safe and appropriate. The premises based risk assessment must include an assessment of fire separation since defects would place vulnerable residents at significant risk.

Competence of Fire Risk Assessors

142. Risk assessors must be competent.  Whoever carries out the assessment should have skills and knowledge commensurate with the complexity of the premises and the vulnerability of the residents.  Building owners or management should decide whether their employees have the capability to assess fire risk. If they do not have sufficient resources or skills in-house, they can arrange for a suitably qualified external person or company to carry out an assessment. 

143. It is important to know that an external fire risk assessor is competent but this can be difficult to ascertain.  Those operating in the fire sector or who have previous fire service experience may not necessarily be fire safety specialists.

144. Using registered or third-party certificated persons or firms to carry out fire safety risk assessments is one way to establish competence. The Scottish Government and 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 with 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.  

145. In selecting a fire risk assessor, their competence in the principles of fire safety in specialised housing should be checked.  

146. 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.

147. 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 over precautionary or risk-averse.

A Methodology for Assessing Fire Risk

148. 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.

Figure 1: Fire safety risk assessment process

Step 1: Obtain information

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

• The number of floors and approximate area of each floor.
• Ancillary uses of the building, such as community activities and care services.
• The number and profile of the residents (identify any residents who have difficulty in self-evacuating.  Make reference to the provision of person-centred risk assessments for higher risk residents / PEEPs).
• The presence of staff, such as a sheltered housing scheme manager or care/support staff.
• Staff training.
• Previous history of fires. 
• 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.
• Arrangements for engagement with residents.
• The process for identifying those who require a person-centred fire safety risk assessment.

Step 2: Identify potential causes of fire

150. For a fire to start, three components are needed: a source of ignition, fuel and oxygen.  If one of these components 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 its development.

151. The premises as a whole should be examined to identify potential ignition sources, materials that might fuel a fire and the circumstances where a fire could start.  Specific measures to prevent fire or protect individuals from fire in their private accommodation should be identified through the person-centred process (see Part 1 of the Guidance).  Measures such as fire detection and warning are likely to involve a building-wide strategy, even where separate domestic systems are provided within flats.  These would normally be considered primarily through the premises based risk assessment, with refinements or additional requirements being identified through the person-centred assessment. 

152. Potential causes of fire and measures to eliminate or reduce the likelihood of each cause should be considered, including:

• Fire raising.
• Electrical faults (in fixed wiring and any equipment provided).
• Smoking.
• Cooking.
• Use of portable heaters.
• Contractors’ activities.
• Heating installations.
• Lightning.
• Housekeeping.
• Storage and charging of mobility scooters.

Step 3: Evaluate the risk

153. The risk 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.

154. Having identified potential causes of fire, the chances of a fire occurring should be considered. 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 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, open doors and external wall cladding systems.
• How generic characteristics will affect how residents are likely to respond.
• Fire and smoke affecting the behaviour of residents.
• Fire and smoke spread into the premises from exterior fires.

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

156. Principal fire safety measures to consider are set out in Chapter 5 but include:

• The means of escape from fire.
• Fire separation, particularly the enclosure of private accommodation within fire-resisting construction.  This should ensure adequate separation between units of private accommodation and between private accommodation 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 private accommodation to the nearest stairway or final exit.
• Smoke control within the common areas.
• Emergency escape lighting.
• Fire escape route signs.
• Fire suppression installations provided.

Step 4: Decide if existing Fire Safety Measures are adequate

157. Existing fire safety measures to prevent fire and provide protection in the event of fire are assessed to decide if they are adequate, or if more needs to be done. The level of fire safety measures provided in premises should be proportionate to the level of risk to people’s safety and will therefore vary between premises (see Chapter 5). 

158. Measures to assist SFRS, such as rising fire mains and firefighters lifts may have been required under Building Regulations at the time of construction.  

159. Maintenance of fire safety measures should be verified (see Part 3 of this Guidance).  This is a requirement of the Fire Safety (Scotland) Regulations 2006 for measures provided for the safety or use of firefighters.

Step 5: Formulate an Improvement Plan

160. An Improvement Plan should be produced, setting out the actions from the risk assessment.  This is a list of preventative, protective or managerial measures to ensure that fire risk is maintained at, or reduced to, an acceptable level. It may be worth consulting with residents on any proposed improvements.  The actions should be reasonably practicable, taking cost, effort and risk into account. They should be prioritised and have timescales for completion unless all measures are relatively minor and can be implemented in a short time.  

161. If existing fire safety measures are adequate and no improvements are necessary, this should be recorded in the fire safety risk assessment findings.

162. Improvements involving building work should be done in accordance with Building Regulation procedures. The Improvement Plan should also include any specific measures and precautions that need to be taken during upgrade work.  

Step 6: Record the findings

163. The significant findings from the fire safety risk assessment, and any action taken, should be recorded and retained.  This is a legal requirement for those premises where fire safety law applies and which have either 5 or more employees, or where a licence (such as an HMO licence) or registration under an enactment is required (for example, care services registered with the Care Inspectorate).  Although no particular format is required, a template is provided in Annex 5.  

164. The significant findings, including any improvement plan, should be shared with the landlord / housing provider.  A summary of the significant findings or, if required, a full copy of the completed fire safety risk assessment should also be available to residents on request.

Step 7: Review

165. The fire safety risk assessment should be reviewed regularly. A date for the next review should be set at the last assessment. It should also be reviewed:

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

166. A review is not necessarily a repeat of the entire fire safety risk assessment process.  A shorter review exercise might be carried out regularly, with a full risk assessment completed less frequently.

167. As a general guide, for low risk sheltered housing, an annual review might be appropriate, with a new fire safety risk assessment every three years.  For higher risk accommodation, taking into account considerations such as resident vulnerability, building age/complexity, management controls, a full annual risk assessment might be more appropriate.

168. Reviews may be carried out by suitably trained, competent in-house staff, as they are about identifying changes and checking progress of the improvement plan. This can reinforce ownership of fire safety management, as well as developing knowledge and a positive fire safety culture.