What Does the Regulatory Reform (Fire Safety) Order 2005 Require?

Quick Answer: The Regulatory Reform (Fire Safety) Order 2005 (RRO) is the primary fire safety law for non-domestic premises in England and Wales. It places duties on the "responsible person" to carry out a fire risk assessment, implement general fire precautions (detection, escape routes, emergency lighting, signage, fire-fighting equipment), maintain those precautions, and train staff. Enforcement is by local fire and rescue authorities, with penalties including unlimited fines and imprisonment.

Summary

The RRO came into force on 1 October 2006, consolidating over 70 pieces of previous fire safety legislation into a single framework. It replaced the old fire certificate system — under which businesses had to obtain certificates from the fire authority — with a self-assessed, risk-based approach where the responsible person takes ownership of fire safety management.

The shift to self-assessment placed greater responsibility on building owners, occupiers, and employers. The fire authority's role moved from pre-emptive certification to enforcement of the duty to self-assess and to maintain adequate precautions. Fire authorities can and do carry out inspections, issue enforcement notices, and prosecute where standards are not met — but they do so reactively, without the safety net of pre-cleared fire certificates.

The RRO applies to virtually all non-domestic premises. It does not apply to single private dwellings, but it does apply to the common areas of blocks of flats, HMOs, sheltered housing, and other multi-occupied residential buildings. The Fire Safety Act 2021 extended the RRO to cover the structure, external walls, and flat entrance doors of multi-occupied residential buildings.

Key Facts

Quick Reference Table

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RRO Article Requirement Key Point
9 Fire risk assessment Suitable and sufficient; reviewed regularly; recorded if 5+ employees
10 Principles of prevention Prefer elimination to control; hierarchy of risk reduction
11 General fire precautions Umbrella duty covering Articles 13–22
13 Fire-fighting and detection Appropriate equipment; automatic detection where needed; testing and maintenance
14 Emergency routes and exits Sufficient number and capacity; kept clear; emergency lighting
15 Emergency procedures Written emergency plan; drills; nominated persons
16 Fire safety measures for dangerous substances Additional duties where flammable/explosive materials are present
17 Maintenance All fire precautions maintained in efficient working order
18 Safety assistance Appoint competent persons to help comply
19 Inform employees Information on risks, precautions, emergency plan, nominated fire wardens
20 Inform employers from outside undertakings Duty to inform contractors' employees on site
21 Training Induction training; periodic refresher; appropriate and recorded
22 Cooperation and coordination Multiple occupants must cooperate; exchange info
32 Offences Criminal liability for responsible person; due diligence defence available

Detailed Guidance

The Responsible Person

The "responsible person" is the person on whom the RRO's duties fall. Article 3 defines this as:

In a building with multiple occupants — for example, a commercial office building with several tenant companies — each employer is the responsible person for their own demised area. The building owner or managing agent is the responsible person for common areas. The RRO (Article 22) requires all responsible persons in a building to cooperate and share information relevant to fire safety.

The Building Safety Act 2022 introduced the concept of the "Accountable Person" for higher-risk residential buildings — a more specific designation with more onerous duties than the RRO's responsible person, for buildings over 18m or 7 storeys.

General Fire Precautions (Article 11)

Article 11 requires the responsible person to implement "general fire precautions" to the extent necessary to reduce the risk to relevant persons (employees, and others lawfully on the premises) to as low as reasonably practicable. These precautions are detailed in Articles 13 to 22.

Fire detection and warning (Article 13): The premises must have appropriate fire detection (where the risk assessment identifies a need for automatic detection) and a means of giving warning (manual call points, automatic alarms, or voice alarm systems). The appropriate level of detection depends on the size and nature of the premises, sleeping risk, and the fire risk assessment findings. All detection equipment must be maintained in working order.

In a small single-storey open-plan office with clear sight lines and few people, a manual alarm (air horn) may be sufficient. In a multi-storey building with hidden areas, sleeping risk, or a large number of occupants, automatic detection linked to a central fire alarm panel with appropriate coverage is required.

Fire-fighting equipment (Article 13): Appropriate fire-fighting equipment must be provided — typically portable fire extinguishers, and in some cases hose reels, dry or wet risers, or suppression systems. Extinguishers must be of the correct type for the potential fire classes present (Class A — wood/paper; Class B — flammable liquids; Class C — gas; Class E/electrical; Class F — cooking oils). They must be serviced annually by a competent person.

Emergency routes and exits (Article 14): The number, capacity, and location of emergency exits must be sufficient for the number and nature of occupants. Escape routes must:

Emergency procedures (Article 15): A written emergency plan must be prepared. It must cover:

The plan must be shared with employees and, where relevant, with employees of other undertakings on the premises.

Maintenance (Article 17)

Article 17 places a duty to maintain all means of escape, fire-fighting equipment, detection systems, and other fire safety measures in "efficient working order and in good repair." This is not a passive duty — it requires active monitoring and testing.

Key maintenance obligations include:

Records of all maintenance and tests must be kept and made available to the enforcing authority on request.

Staff Information and Training (Articles 19, 21)

The responsible person must ensure that employees are given appropriate fire safety information and training. The RRO specifies that this must be:

Training must cover:

Nominated fire wardens (marshals) require additional training proportionate to their responsibilities — typically including how to search a floor, ensure evacuation is complete, liaise with the fire service, and use extinguishers.

Enforcement and Penalties (Articles 30–32, 45)

Local fire and rescue authorities are the enforcing authority for the RRO. Fire inspectors have powers to:

The RRO creates criminal offences for failure to comply with Articles 8 to 22 and with enforcement notices. Defences include due diligence (taking all reasonably practicable steps) and, in some cases, acting in reliance on incorrect information from another responsible person.

Penalties on conviction:

High-profile prosecutions have resulted in fines running into hundreds of thousands of pounds for organisations and custodial sentences for individuals.

Interaction with Other Legislation

The RRO exists alongside, not instead of, other fire safety-related legislation:

Where the RRO and HSW Act overlap, complying with one does not automatically mean compliance with the other, but carrying out a thorough fire risk assessment under the RRO will generally satisfy the fire-related elements of the HSW Act assessment.

Frequently Asked Questions

Does the RRO apply to my rental property?

The RRO applies to the common parts of a building containing multiple dwellings — so the stairwells, corridors, and shared areas of an HMO or block of flats are within scope. Individual let flats or houses occupied by a single household are outside the RRO's scope, but landlords have duties under the Housing Act 2004, Smoke and Carbon Monoxide Alarm (England) Regulations 2015, and other legislation. From 2021, the Fire Safety Act extended the RRO to cover the external walls, structure, and flat entrance doors of multi-occupied residential buildings.

Is a fire certificate still required?

No. The fire certificate system was abolished when the RRO came into force on 1 October 2006. All existing fire certificates became null and void. They may still contain useful information about the building's fire precautions and history, but they carry no legal status and do not exempt anyone from the duties imposed by the RRO.

Who enforces the RRO for care homes and hospitals?

Fire and rescue authorities are the primary enforcing authority. However, the Care Quality Commission (CQC) also considers fire safety as part of its inspection regime for care homes and hospitals — inadequate fire safety can result in CQC enforcement action or conditions on registration. The two enforcement regimes operate independently but often coordinate.

What is a "suitable and sufficient" fire risk assessment?

This is the standard the RRO requires but does not define precisely. Guidance from the Home Office and NFCC suggests that an assessment is suitable and sufficient when it:

It is not a question of length or format — a short, focused assessment for a simple low-risk premises is more likely to be suitable and sufficient than a lengthy generic document that does not address the specific conditions.

Regulations & Standards