The Role of the Fire Risk Assessor in Evaluating Passive Fire Systems in the UK

Introduction

Passive Fire Protection (PFP) forms an essential component of a building’s fire safety strategy. Unlike active fire protection—which includes sprinklers, alarms, extinguishers—passive systems are built into the structure (fire-rated doors, walls, floors, compartmentation, coatings, etc.) and work constantly to limit the spread of fire, heat, and smoke.

Under UK law, fire safety duties fall mainly under:

• The Regulatory Reform (Fire Safety) Order 2005 (FSO) for most non-domestic premises.

• The Building Regulations, especially Approved Document B (fire safety), which gives technical guidance for passive protection in design and construction.

• Other legislation, like the Fire Safety Act 2021 and Fire Safety (England) Regulations 2022, which clarify and expand duties in multi-occupied residential buildings, including external walls and flat entrance doors.

A Fire Risk Assessor plays a central role in ensuring that passive fire systems are adequate, compliant, and maintained. Below I outline what their responsibilities are, what they must check, what standards they must apply, and challenges typically faced.

What is Expected of a Fire Risk Assessor Related to Passive Fire Systems Competency and qualifications

• Must be a competent person. UK guidance and industry bodies stress that assessors have the necessary training, knowledge, experience, and professional accreditation.

• Newer standard: BS 8674 (2025) – Built Environment – Framework for Competence of Individual Fire Risk Assessors. It sets out levels (Foundation, Intermediate, Advanced) to match different types of building complexity.

Inspection of passive fire protection systems

When assessing a building, the assessor should evaluate:

• Compartmentation: fire-resistant walls, floors, ceilings, to prevent fire spreading beyond its origin, especially protecting escape routes. Check for breaches: unsealed penetrations, gaps, improperly fitted doors or walls.

• Fire doors and smoke doors: their fire resistance ratings (e.g. FD30, FD60 etc.), the condition of seals, the closing mechanism, gaps, signage. Doors between flats and common parts are legally significant.

• Fire stopping / fire seals: around pipework, ducts, cable routes etc. Are they properly installed and maintained? Are materials still intact? Any damage from subsequent works?

• Structural fire resistance: walls, floors, roof structures; also, external walls’ materials and cladding (especially post-Grenfell scrutiny) must meet fire resistance and performance requirements. Standards like BS 8414 are relevant for external systems.

Verification of documentation and historic compliance

• Regulation 38 (under the Building Regulations) requires those carrying out construction works involving fire safety systems to hand over relevant documentation (what was installed, who by, performance data, maintenance instructions) to the responsible person. This documentation is vital for assessors.

• Checking whether past inspections, maintenance records, tests etc. are up-to-date. Are there certificates for fire-rated doors, drilled penetrations, passive fire materials, fire-resisting partitions?

Assessment of maintenance and deterioration

• Passive fire protection systems degrade over time or during work: holes drilled, doors warped, seals damaged or removed, coatings or intumescent materials deteriorated etc. The assessor must check for these.

• They should identify whether regular inspections or surveys have been carried out, and whether repairs (if required) are being done.

Risk evaluation and recommendations

• Based on findings, the assessor must assess whether the current passive fire protection is sufficient for the building’s use, occupancy, layout, hazards.

• If deficiencies are discovered, recommend remedial actions: upgrading doors, sealing penetrations, improving compartmentation, replacing non-compliant materials, etc.

• Prioritise recommendations: What is critical to life safety? What can be deferred?

Legal and regulatory compliance

• Ensure assessment aligns with Regulatory Reform (Fire Safety) Order 2005: the responsible person must carry out a suitable and sufficient fire risk assessment; the assessor helps fulfil that duty.

• Consider recent legislative changes: Fire Safety Act 2021, Fire Safety (England) Regulations 2022, as they bring into scope more elements (external walls, flat entrance doors).

• Use British Standards and approved codes: for example BS 476, BS EN 1366 for fire tests; PAS 79 for documenting risk assessments.

Follow-up, monitoring and review

• Fire risk assessments are not one-off. The assessor should recommend periodic reviews, especially after changes: refurbishment, change in building use, unusual damage or deterioration.

• Ensure responsible person has systems in place to monitor and maintain PFP elements.

Key Legal / Regulatory Instruments & Standards

• Regulatory Reform (Fire Safety) Order 2005 – duty of the Responsible Person to ensure suitable & sufficient fire risk assessment; ongoing management.

• Building Regulations, Approved Document B (Fire Safety) – technical requirements for passive fire protection in new and existing buildings.

• Fire Safety Act 2021 – clarifications about what the FSO covers (external walls, flat entrance doors) in multi-occupied residential buildings.

• Fire Safety (England) Regulations 2022 – obligations for medium and high rise buildings regarding external wall safety information, fire doors etc.

• British Standards & Codes of Practice:

• BS 8674 (2025) – competence of fire risk assessors.

• BS 476, BS EN 1366 – fire resistance testing.

• PAS 79 – structure and documentation of fire risk assessments.

Challenges and Common Pitfalls

• Poor documentation: Many buildings lack full records of what passive fire systems were installed, performance ratings, maintenance history. This makes accurate assessment difficult.

• Unnoticed damage or changes: During renovations or building alterations, passive fire protection (e.g. seals, doors, wall penetrations) may be compromised and not restored correctly.

• Variability in competence of assessors: While new standards help, difference remains in experience, quality of report, interpretation of what is “suitable & sufficient.”

• Cost vs safety, balancing budget constraints with necessity: sometimes responsible persons resist expensive upgrades, but legal duty and liability remain.

• Interplay between passive and active systems: Passive systems alone do not extinguish fire. It’s important for assessors to consider how active systems (alarms, sprinklers, suppression) complement passive protection in risk reduction.

A Fire Risk Assessor’s role in relation to passive fire systems is pivotal: they ensure structural, material, and installation integrity; verify maintenance; apply legal, regulatory and standards-based benchmarks; and help ensure that both occupants’ safety and building compliance are met. With evolving legislation (e.g., Fire Safety Act, FSER 2022) and increased scrutiny (especially after major building fires), the assessor’s role becomes even more critical.