This Information Sheet has been prepared by Marpal Fire Safety Limited and discusses recent developments in fire risk assessment guidance and competency standards that may prompt organisations, particularly care providers, to review their arrangements for undertaking Fire Risk Assessment reviews.
Background
The fire safety sector continues to evolve at pace. Since the Grenfell Tower tragedy, there has been a significant focus on improving competence across the built environment, including those responsible for carrying out Fire Risk Assessments (FRAs).
Government, industry bodies and professional organisations have all emphasised the importance of ensuring that fire safety decisions are made by individuals with appropriate knowledge, skills, experience and professionalism. Whilst much of this focus has been directed towards the completion of new FRAs, the competency requirements associated with reviewing existing assessments are receiving increasing attention.
Many care providers currently commission a FRA from an external specialist organisation every two or three years and undertake annual reviews internally. However, as guidance develops and expectations around competence continue to rise, organisations may need to reconsider whether internal reviews remain an appropriate approach.
Current Guidance for Fire Risk Assessment Reviews
The two principal guidance documents currently providing direction on FRA reviews are:
- PAS 79-1:2020 – Fire Risk Assessment for Premises Other Than Housing
- BS 9792:2025 – Housing Fire Risk Assessment Code of Practice
Both documents provide guidance on undertaking suitable and sufficient Fire Risk Assessments and include provisions relating to the review of existing assessments.
PAS 79-1:2020
PAS 79-1 makes only a single direct reference to the reviewer being a Fire Risk Assessor (Paragraph 20.5). However, Annex D contains a model review template that requires the reviewer to consider a range of technical fire safety matters, including:
- Are the means of escape from fire adequate?
- Are compartmentation and internal linings satisfactory?
- Is emergency lighting adequate?
- Are the means of giving warning of fire adequate?
- Are arrangements for managing fire safety adequate?
- Have previous recommendations been satisfactorily addressed?
These are not simple administrative ‘tick box’ checks.
To answer such questions appropriately, the reviewer must possess a detailed understanding of fire safety legislation, guidance, fire protection systems, means of escape, compartmentation principles and fire safety management arrangements. Where remedial building works have been undertaken, the reviewer must also be capable of determining whether those works adequately address the recommendations of the previous assessment.
BS 9792:2025
BS 9792 adopts a more explicit approach and repeatedly refers to the reviewer as a Fire Risk Assessor.
Examples include:
- “The extent of the review is determined by the reason for the review and the judgement of the Fire Risk Assessor.”
- “If during the course of a review, the Fire Risk Assessor identifies that a full and thorough inspection has not been completed as part of the previous FRA, it is appropriate to recommend to the duty holder that a completely new FRA be undertaken.”
- “When the FRA is being reviewed, if it becomes apparent to the Fire Risk Assessor that the previous FRA or review was not adequate, they should recommend to the duty holder that a completely new FRA be undertaken.”
- The review should consider changes to occupants, hazards, fire protection measures, fire safety management arrangements and the likely consequences of fire.
- The review should record the name of the Fire Risk Assessor carrying out the review.
Unlike PAS 79-1, BS 9792 does not include a simple review proforma. Instead, it places reliance on the judgement and competence of the Fire Risk Assessor undertaking the review.
Why the Care Sector Is Different
The competence question becomes particularly important within the care sector.
In many premises, fire risk is primarily determined by the building, its fire precautions and the activities taking place within it. In care settings, however, the risk profile is often heavily influenced by the characteristics of the residents themselves.
Factors that may significantly affect fire risk include:
- Dementia and other cognitive impairments.
- Mental health conditions.
- Learning disabilities.
- Residents’ dependent upon oxygen.
- Behavioural challenges e.g. hoarding.
- Reduced mobility necessitating staff assistant for evacuation.
- Bariatric residents who cannot easily be evacuated.
- Changes in dependency levels.
- Staffing levels, particularly at night.
- Residents with a history of fire starting.
- Residents who cannot smoke safely without staff assistance/supervision.
These factors can change rapidly and may have a substantial impact on evacuation strategies, staffing requirements and overall fire risk.
A review of a Fire Risk Assessment therefore requires consideration of far more than whether fire safety systems and the fabric of the building have been adequately maintained. It requires an assessment of how changes within the resident population may affect the suitability of existing fire precautions and emergency procedures.
It is difficult to envisage how a Care Home Manager, Office Manager or Head Teacher with limited fire safety training and little practical experience of carrying out FRAs could reasonably be expected to make these judgements with confidence.
The Competence Agenda
The increasing emphasis on competence should not come as a surprise.
Following the Grenfell Tower Inquiry and the recommendations arising from Dame Judith Hackitt’s Independent Review of Building Regulations and Fire Safety, the fire sector has seen a significant shift towards demonstrating competence rather than simply claiming it.
This shift is reflected across numerous industry initiatives, including third-party certification schemes, professional registers and competency frameworks.
Perhaps the clearest example is BS 8674:2025 – Framework for Competence of Individual Fire Risk Assessors. The standard leaves little doubt about the extensive knowledge, skills and experience expected of those undertaking Fire Risk Assessments.
For example, Fire Risk Assessors seeking registration on the National Fire Risk Assessors Register at Advanced Level (typically required for high-risk premises such as care homes) are expected to demonstrate:
- Significant experience carrying out Fire Risk Assessments on high-risk premises.
- A Level 5 qualification in a relevant discipline.
- Registration under a recognised third-party accreditation scheme.
- Submission of recent Fire Risk Assessments for technical scrutiny.
- Appropriate professional membership, such as the Institute of Fire Engineers (IFE) or Institute of Fire Safety Managers (IFSM).
- Ongoing Continuing Professional Development (CPD).
These expectations illustrate the level of competence increasingly associated with those undertaking Fire Risk Assessments and, by implication, those reviewing them.
Are Internal Reviews Becoming Obsolete?
Current guidance does not explicitly prohibit internal reviews, nor does it state that every review must be undertaken by an externally appointed consultant.
However, the guidance consistently assumes that reviews are undertaken by individuals acting in the capacity of Fire Risk Assessors and capable of exercising professional judgement on technical fire safety matters.
As expectations around competence continue to increase, organisations should carefully consider whether those undertaking internal reviews possess the necessary knowledge, skills, experience and independence to fulfil that role.
For organisations operating higher-risk premises, particularly care homes accommodating vulnerable residents, this is an important question.
Conclusion
Whichever guidance document is considered, references to FRA reviews consistently assume that the review is being undertaken by a Fire Risk Assessor. The review process requires the reviewer to make professional judgements regarding fire safety management arrangements, fire protection measures, means of escape, the adequacy of previous remedial works, and whether a previous assessment remains suitable and sufficient.
In many premises, these judgements may be beyond the knowledge and experience of individuals whose primary role is not fire safety. This is particularly relevant within the care sector, where fire risk is influenced not only by the physical characteristics of the building but also by the changing needs, behaviours and vulnerabilities of residents.
Factors such as dementia, mental health conditions, mobility impairments, behavioural challenges, sleeping risk, medication, staffing levels and evacuation capability can significantly affect the overall fire risk profile of a care setting. These factors may change considerably between formal assessments and require careful evaluation by a competent Fire Risk Assessor.
The direction of travel within the fire sector is increasingly towards demonstrable competence, supported by recognised qualifications, experience and third-party accreditation. While current guidance does not explicitly prohibit internal reviews, organisations should carefully consider whether those undertaking reviews possess the necessary competence to evaluate both the physical and management aspects of fire risk.
For many care providers, the question is no longer whether a review can be undertaken internally, but whether the person undertaking that review can demonstrate the competence expected of a Fire Risk Assessor.
About Marpal Fire Safety
Marpal Fire Safety Ltd is a third-party accredited Fire Risk Assessment company specialising in the care sector. We operate under the BAFE SP205 Life Safety Fire Risk Assessment Scheme and utilise experienced Advanced Level Fire Risk Assessors. Our goal is to provide professional advice, guidance and ongoing support services in order to create a healthy, safe working and living environment.
Services Available Include: –
- Fire Risk Assessments
- Fire Compartmentation Surveys
- Fire Safety Consultancy
- Fire Evacuation Strategies
- Fire Safety Policies & Procedures