The Regulatory Reform (Fire Safety) Order 2005 (RRFSO or "the Order") is the primary piece of fire safety legislation for non-domestic premises in England and Wales (Scotland and Northern Ireland have their own equivalent legislation). It replaced a patchwork of over 70 pieces of earlier fire safety legislation with a single, self-assessed duty. Since the Grenfell Tower fire in 2017 and the subsequent Building Safety Act 2022, enforcement of the Order has tightened considerably.
The responsible person. Article 3 of the Order defines the "responsible person" as the employer, if the workplace is under their control, or otherwise the person who has control of the premises — typically the building owner, landlord, or managing agent. This person carries the legal duty under Article 9 to make a "suitable and sufficient" assessment of the risks. Article 17 places a specific duty on the responsible person to ensure fire safety systems are subject to a suitable system of maintenance.
What a suitable and sufficient assessment covers. A compliant fire risk assessment identifies fire hazards, identifies people at risk, evaluates and reduces the risk, and records findings, an emergency plan, and details of any review. The Fire Safety Act 2021 clarified that scope explicitly includes external wall systems and flat entrance doors in multi-occupied residential buildings — a direct response to Grenfell. The Fire Safety (England) Regulations 2022 introduced additional duties for high-rise residential buildings over 11m.
Competence requirements. The Order does not mandate a specific qualification, only that the assessor be "competent" — but regulatory guidance increasingly points to nationally recognised competency frameworks, with PAS 8673 (competence criteria for fire risk assessors) now referenced directly by many enforcing authorities.
How this shapes system design. The fire risk assessment should directly instruct fire alarm category selection, the extent of emergency lighting coverage, fire damper and smoke control specification, and whether voice alarm to BS 5839-8 is warranted. On refurbishment and change-of-use projects, we insist on seeing the current fire risk assessment before finalising a fire alarm specification.
| Requirement | What the Order actually says | Common misconception |
|---|---|---|
| Who must assess | The "responsible person" | "The fire brigade tells us what's needed" |
| Frequency of review | Reviewed when circumstances change | "Once done, never needs revisiting" |
| Competence | Must be "competent" — no single mandated qualification | "Any risk assessment template will do" |
| Enforcement | Fire and Rescue Authorities can prosecute | "It's guidance, not law" |
| Scope | Includes external walls and flat entrance doors | "Cladding is a separate Building Safety Act issue only" |
Common mistakes
The most damaging mistake is treating a fire risk assessment as a one-off compliance exercise rather than a living document. A second common failure is commissioning generic assessments that don't engage meaningfully with the building's specific fire strategy or cause-and-effect philosophy.
Future outlook
The Building Safety Act 2022's "golden thread" of information requirement is pushing fire risk assessment documentation towards a continuously maintained, auditable digital record rather than a static PDF filed away after handover.