Fire Risk Assessment: When Tradespeople Must Carry One Out and What It Covers

Quick Answer: Under the Regulatory Reform (Fire Safety) Order 2005 (updated by the Fire Safety Act 2021 and Building Safety Act 2022), every "responsible person" for non-domestic premises and the common parts of multi-occupied residential buildings in England and Wales must carry out and keep current a Fire Risk Assessment (FRA). Tradespeople become responsible persons (or are duty-bound to support FRAs) when they own/operate workshops, yards or offices, and when working in commercial or HMO properties. From 1 October 2023 the FRA must be recorded in writing for premises with 5+ employees, residential common parts, or higher-risk premises. Penalties for non-compliance can reach unlimited fines and 2 years' imprisonment for serious offences. Typical FRA costs are £180–£800 for a small commercial premises, £400–£1,800 for a residential block.

Summary

Fire safety in UK premises (other than single-family domestic homes occupied by their owners) is governed by the Regulatory Reform (Fire Safety) Order 2005 — the FSO. This places the duty for fire safety on a "responsible person" — usually the owner, employer or person in charge of the premises. The FSO replaced the old Fire Certificate regime (where local fire authorities issued certificates) with a self-assessment regime where the responsible person carries out their own Fire Risk Assessment.

For tradespeople, FRA obligations come from three angles:

1. Owner/operator — if you operate a workshop, yard, office, or any premises other than your own dwelling, you (or your business) are the responsible person and must carry out an FRA.
2. Working on others' premises — when carrying out trade work on commercial or multi-occupancy residential premises, the responsible person remains the building owner/operator, but contractors have CDM duties and must follow the building's fire safety procedures.
3. Specifying fire-related works — installations affecting fire safety (fire doors, compartmentation, escape routes, alarm systems, suppression systems) must be specified to comply with current Building Regulations Approved Document B and the building's existing FRA.

The Grenfell Tower fire (2017) and the resulting Building Safety Act 2022 have significantly raised the regulatory bar — particularly for higher-risk buildings (over 18m or 7 storeys, or with 2+ residential units in scope). Tradespeople working on cladding, fire stopping, compartment lines, fire doors and escape routes are now potentially liable for non-compliance, even where the work is years old.

Key Facts

• FRA legal duty — Regulatory Reform (Fire Safety) Order 2005, Article 9 — every responsible person must carry out an FRA
• Written record requirement (from 1 October 2023) — premises with 5+ employees, residential common parts, or higher-risk premises must record FRA in writing
• Review frequency — FRA must be kept under review; reviewed when significant changes occur, and at least annually as best practice
• Premises in scope — all non-domestic premises and common parts of multi-occupied residential buildings (HMOs, blocks of flats)
• Premises NOT in scope — single-family private dwellings (i.e. inside the front door of an owner-occupied house)
• Higher-risk buildings (Building Safety Act 2022) — over 18m or 7+ storeys with 2+ residential units; under Building Safety Regulator (HSE)
• Responsible person — owner, employer, person in control, or landlord (in some cases multiple parties share duty)
• Competent person — someone with sufficient training and experience to carry out an FRA; for higher-risk premises, a fire engineer with formal qualifications (e.g. IFE Member, FRA-Cert)
• FRA cost — small office or shop — £180–£600 typical
• FRA cost — larger commercial or residential block — £400–£1,800 typical
• FRA cost — higher-risk building (18m+) — £900–£5,000+
• Five steps of FRA — identify hazards, identify people at risk, evaluate/remove/reduce risks, record findings + plan, review and revise
• Fire Safety Act 2021 — confirms that the building's external walls and flat entrance doors are within the FRA scope
• Penalties — fines (unlimited for serious offences) and imprisonment up to 2 years for individuals
• Insurance — most commercial insurers require a current written FRA; without it, claims may be refused

Quick Reference Table — FRA Requirement by Premises Type

Detailed Guidance

The five-step FRA process

The HMRC and HSE-aligned process (per HM Government guidance):

1. Identify fire hazards — sources of ignition (heaters, electrical, smoking), sources of fuel (furniture, paper, packaging, fuels stored), oxygen supply (ventilation, oxygen cylinders).
2. Identify people at risk — employees, visitors, vulnerable occupants (mobility, hearing, learning disabilities), people working alone, sleeping occupants (HMOs, hotels).
3. Evaluate, remove, reduce or protect from risks — ignition source removal, fire-resistant materials, separation, suppression, detection, escape routes.
4. Record findings, prepare emergency plan, train staff — written FRA, evacuation plan, fire drill records, staff training records.
5. Review and revise — annually as best practice; immediately on any significant change.

When tradespeople must commission an FRA

A tradesperson becomes a responsible person when they:

• Operate any non-domestic premises (workshop, yard, office, store)
• Employ 5+ people in any business location
• Run an Airbnb or short-let with sleeping occupants
• Manage rental property (landlord)

In these cases, commission a competent person to carry out the FRA. Cost: £180–£800 typical for a small premises. Update annually or on significant change.

Working on others' premises — fire safety implications

When carrying out trade work on commercial or multi-occupancy residential premises:

• Read the existing FRA — know what fire risks the premises has identified, what mitigation is in place
• Don't compromise compartmentation — fire doors, fire walls, fire-rated ceilings; if you cut a hole, fire-stop it back to the original rating
• Don't block escape routes — temporary works storage, scaffold, materials must not block fire exits
• Hot work permit (where applicable) — welding, cutting, soldering, blow-torches: require permit-to-work in many commercial premises
• Fire-stopping work — must comply with BS 9991 (residential), BS 9999 (non-residential), or specific compartment fire-rated detail

Higher-risk buildings — Building Safety Act 2022

For buildings 18m+ or 7+ storeys with 2+ residential units:

• Building Safety Regulator (HSE) — registers the building, assesses safety case
• Accountable Person — duties to manage risk including FRA
• Principal Accountable Person — has overall duty; usually freeholder or building owner
• Safety Case — periodic full review of fire and structural risks
• Building Safety Manager (BSM) (where applicable) — day-to-day oversight

Tradespeople working on these buildings face higher scrutiny on materials, methods, and certification. Cladding work since Grenfell is particularly scrutinised — Class A1 or A2 reaction-to-fire required for buildings 11m+.

Cladding and fire — the post-Grenfell environment

The Fire Safety Act 2021 confirmed that the external walls (including cladding, balconies, attachments) and flat entrance doors are part of the FRA scope. Implications:

• Buildings 11m+ require external wall fire reviews (EWS1 forms previously, now updated through the Building Safety Act framework)
• Cladding made of combustible materials has been removed or remediated through government schemes (Building Safety Fund, Cladding Safety Scheme)
• Fire-rated cavity barriers and fire-stopping at compartment lines must be intact

Tradespeople specifying or installing cladding, balconies or external work must verify compliance with current Approved Document B and BS 8579 (balconies and terraces) and BS 8414 (cladding fire performance).

Fire doors — the most common compliance gap

Fire doors are critical in compartmentation. Common issues found in FRAs:

• Damaged seals (intumescent or smoke seals)
• Damaged door leaf
• Missing self-closer
• Wedged open
• Excessive gap between leaf and frame
• Wrong-rated door (fitted FD30 where FD60 required)
• Painted-over hinges and ironmongery

Tradespeople carrying out fire door installation should:

• Use fire-rated certified door sets (third-party certified, e.g. BWF-CERTIFIRE, IFC-Certified)
• Keep installation records (door schedule, certification)
• Ensure self-closer fitted, intumescent and smoke seals intact
• Ensure ironmongery is fire-rated (hinges, latches, locks)

Cost of replacing a single fire-rated door (FD30, certified): £400–£900 supply and fit. For FD60: £600–£1,400.

Annual review — what to check

The annual FRA review checks:

• Have any changes occurred in the building, occupants, or activities?
• Are previously identified actions still complete and effective?
• Are escape routes still clear?
• Is fire detection and alarm system still functioning?
• Are emergency lights tested?
• Are fire-fighting equipment in date?
• Is staff training up to date?
• Have there been any near-misses or incidents?

A formal annual review by the responsible person, with sign-off, satisfies the "kept under review" duty.

Frequently Asked Questions

Do I need an FRA for my workshop or trade yard?

If you have 5+ employees or contractors regularly on site, yes — written FRA required. Less than 5, FRA is still required by law but doesn't have to be in writing (best practice to write it anyway for insurance purposes).

Can I do my own FRA?

Yes for low-risk premises (small office, simple workshop). For complex premises (sleeping accommodation, large commercial, higher-risk buildings), commission a competent fire risk assessor. Cost £180–£800 for small, £400–£1,800 for residential blocks, more for higher-risk buildings.

What happens if I don't have an FRA?

Penalties under the Regulatory Reform (Fire Safety) Order 2005:

• Minor offences: fixed penalty notices, fines up to £5,000
• Serious offences: unlimited fines, 2 years' imprisonment for individuals
• Insurance: claim refused if FRA not maintained

How often should the FRA be reviewed?

At least annually as best practice. Immediately when significant changes occur (new tenant, new layout, new processes, new occupant types, fire incident, near-miss).

Does the FRA cover gas boilers and electrical installations?

Yes — gas appliances, electrical installations, lithium battery storage are all fire risks within FRA scope. The FRA references compliance with separate regulations (Gas Safe, BS 7671) but identifies the fire risk and mitigation.

Regulations & Standards

• The Regulatory Reform (Fire Safety) Order 2005 (FSO) — primary UK fire safety law

• The Fire Safety Act 2021 — confirms external walls and flat entrance doors within scope

• The Building Safety Act 2022 — establishes higher-risk building regime

• The Fire Safety (England) Regulations 2022 — implements FSA 2021 requirements

• Building Regulations Approved Document B — fire safety in buildings

• BS 9991:2024 — fire safety in design, management and use of residential buildings

• BS 9999:2017 — fire safety in design, management and use of buildings (non-residential)

• BS 8214:2016 — code of practice for fire door assemblies

• BS 5266 series — emergency escape lighting

• BS 5839 series — fire detection and alarm systems

• BS 8414 series — cladding fire performance

• PAS 79-1:2020 — fire risk assessment for premises (non-residential)

• PAS 79-2:2020 — fire risk assessment for residential premises

• Fire Safety Order — Regulatory Reform (Fire Safety) Order 2005 — UK primary fire safety legislation

• HM Government — Fire safety in your business — official guidance

• Fire Safety (England) Regulations 2022 — recent regulations

• Building Safety Regulator (HSE) — higher-risk buildings regulator

• Institution of Fire Engineers — UK professional body for fire engineers

• CDM Regulations for construction safety duties

• building regulations overview including Approved Document B

• competent person schemes for self-certification

• landlord certificates including fire safety duties