Purpose
What did the Fire Safety Act change?
Section 1 clarified the scope of the Fire Safety Order for buildings containing two or more sets of domestic premises. The responsible person must consider the building’s structure, external walls and doors between domestic premises and common parts when carrying out and acting on the FRA.
This removed doubt about whether those elements fell within the Order. The Act works by amending the existing regime: the responsible person, suitable-and-sufficient test, review duty and enforcement framework remain those of the Fire Safety Order.
Assessment scope
Which building elements must be considered?
External walls include anything forming part of the wall and attachments to it. The assessment must consider risk rather than merely list materials. The appropriate evidence depends on construction, height, vulnerability, evacuation strategy and signs of potential external fire spread.
Structure
The building’s structural elements insofar as they affect fire risk under the Order.
External walls
Wall systems, construction and relevant components, including cladding.
Attachments
Balconies and other items attached to external walls.
Openings
Doors and windows in external walls.
Flat entrance doors
Doors between individual domestic premises and common parts.
Common parts
The established scope of corridors, stairs, plant rooms and relevant shared facilities continues.
Proportionate evidence
When is an external-wall appraisal needed?
The ordinary FRA must consider the external wall, but not every building automatically needs a full fire risk appraisal of external walls under PAS 9980. A competent assessor should identify whether the available information and observable construction are enough or whether a specialist FRAEW is justified.
Where external-wall risk is known or suspected, a competent fire engineer or other appropriately competent building professional may need to undertake the appraisal. The resulting FRAEW informs the wider fire risk assessment; it does not replace it.
- Gather as-built, refurbishment and product information
- Record what could and could not be confirmed
- Consider height, wall build-up, balconies and fire barriers
- Explain whether specialist appraisal or intrusive investigation is needed
- Feed conclusions and actions back into the whole-building FRA
Doors to homes
Flat entrance doors and ongoing checks
Flat entrance doors between domestic premises and common parts must be addressed in the FRA. The assessment should consider their condition, self-closing, fire and smoke performance, alterations and the building’s fire strategy.
Separate duties under the Fire Safety (England) Regulations 2022 require annual checks using best endeavours for flat entrance doors and quarterly checks of communal fire doors in multi-occupied residential buildings above 11 metres. That threshold is not limited to high-rise buildings of 18 metres or seven storeys.
Responsible person
A practical compliance sequence
Start by confirming the responsible person and the premises within scope. Review whether the current FRA explicitly addresses the newly clarified elements and whether its evidence, limitations and competence remain adequate.
Actions may include door repair, improved records, further investigation, interim measures or specialist external-wall advice. Priorities must be based on risk and coordinated with accountable persons where the building is also a higher-risk building under the Building Safety Act.
- Check the FRA scope and date
- Identify construction information gaps
- Inspect and manage flat entrance doors
- Commission specialist advice only where proportionate
- Track actions and revise the FRA when new evidence changes the conclusions