Review duty
Renovation is a common significant-change trigger
Article 9 requires the assessment to be reviewed regularly and where there is reason to suspect it is no longer valid or there has been a significant change in the matters to which it relates. Refurbishment, fit-out, extension, conversion and change of use can all meet that test.
The scale of the review should reflect the effect of the work. Redecoration may require only confirmation that escape routes, signs and fire doors remain unaffected. Replanning floors, adding bedrooms, penetrating compartment walls or changing an evacuation strategy can require a new inspection and substantial revision.
- Change of layout, travel distances or exit capacity
- New occupancy, sleeping use or vulnerable people
- Altered alarms, emergency lighting or smoke control
- New doors, walls, ceilings, risers or service penetrations
- Changes to external walls, balconies or roof systems
- Temporary construction hazards or phased occupation
Construction phase
Manage fire risk before the project finishes
Building work can temporarily increase ignition sources and combustible waste while disabling alarms, doors, escape routes or compartmentation. The occupied-premises responsible person and contractors must coordinate their controls and emergency arrangements.
Review the FRA before work starts and at meaningful phases. Hot work, temporary electrical supplies, hoarding, storage, security, alarm isolations and partial occupation need explicit controls. If an escape route or critical system cannot remain available, decide whether occupation can safely continue.
Plan
Identify fire-safety-critical work, interfaces and temporary arrangements.
Coordinate
Define responsibilities between client, occupiers, principal contractor and other dutyholders.
Control ignition
Manage hot work, temporary power, charging, smoking and arson exposure.
Protect escape
Keep routes, exits, signs and emergency lighting usable or provide justified alternatives.
Manage impairments
Authorise, communicate and time-limit alarm, sprinkler, smoke-control or door impairments.
Inspect phases
Check concealed fire stopping and other critical work before it is covered.
Legal interfaces
Building-control approval is not an operational FRA
Building Regulations govern building work and technical compliance. The Fire Safety Order governs the ongoing management of fire risk in occupied premises. The processes inform one another but neither automatically discharges the other.
For relevant work, Regulation 38 requires fire-safety information to be given to the responsible person by completion or occupation. The handover should describe the design and operation of fire-safety measures clearly enough to support management, maintenance, future alteration and the FRA.
| Process | Main question | Typical evidence |
|---|---|---|
| Building control | Does the building work comply with applicable Building Regulations? | Plans, specifications, inspections and completion documentation. |
| Regulation 38 handover | Has useful fire-safety design and operational information reached the responsible person? | Fire strategy, system descriptions, cause-and-effect, drawings and maintenance information. |
| Fire risk assessment | Are people adequately protected in the premises as actually occupied and managed? | Site inspection, occupancy and management evidence, findings and action plan. |
Completion evidence
What the responsible person should collect and verify
Do not rely on a completion certificate as a substitute for the underlying information. Obtain final, not tender-stage, documents and reconcile them with the as-built premises. Commissioning confirms that a system passed defined tests; it does not prove that every fire-safety measure or operational arrangement is suitable.
Where work affected compartmentation or concealed construction, retain location-specific evidence and inspection records. The FRA should state what could not be verified and whether further survey or opening-up is proportionate.
- As-built layouts and current fire strategy
- Building-control approval and completion information
- Regulation 38 fire-safety information
- Alarm, emergency-lighting and smoke-control commissioning
- Fire-door schedules and inspection evidence
- Fire-stopping locations, products, photographs and installer records
- Updated evacuation plan, signage and staff instructions
- Outstanding defects, limitations and planned completion dates
Before reoccupation
Complete a structured post-work review
The assessor should compare the former assessment, design intent, approved changes and actual installation. Inspect affected escape routes, doors, compartment lines, systems, signs and management arrangements. Reassess people at risk and ensure the emergency plan matches the new layout and occupancy.
Do not wait for the next routine review where the change is material. Record the revised FRA, close urgent actions before occupation where necessary, brief staff and residents, and schedule any follow-up inspection after the building has settled into its new use.
Compare
Identify exactly what changed from the previous FRA and fire strategy.
Inspect
Verify the as-built condition and interfaces, not just the paperwork.
Test evidence
Review commissioning, maintenance baselines and outstanding defects.
Update people
Revise occupancy, assistance needs, training and evacuation arrangements.
Record
Issue a dated revision with limitations and a prioritised action plan.
Monitor
Check snagging, behavioural change and emerging risks after occupation.