ADVICE & OPINION
COMPLIANCE
LIFE SAFETY FIRE RISK ASSESSMENTS
Richard Jenkins, Chief Executive of the National Security
,QsSectorate eSOaiQs the imSOicatioQs of Oife safet\ fi re risN
assessments and how ‘Duty Holders’ can best discharge
their legal responsibilities.
No matter how extraordinary the now routine
pandemic circumstances, it’s important to
not lose sight of fire safety essentials. Even whilst
still coping with the ongoing e ects of COVID-19
and its impact on the use of space and occupancy,
fire risk assessment is a mandatory duty not to be
neglected.
Responsibility for fire safety in a building rests
with the ‘Responsible Person’ or ‘Duty Holder’ under
the Regulatory Reform (Fire Safety) Order 2005 in
England and Wales, the Fire Scotland Act 2005, and
the Fire & Rescue Services (Northern Ireland) Order
2006/Fire Safety Regulations (Northern Ireland)
2010. In the event of a fire, especially should death
or serious injury have occurred, the Fire and Rescue
Service will investigate and, where o ences may
have been committed, prosecution can follow.
ORGANISING A FIRE RISK ASSESSMENT
Life safety fire risk assessment (LSFRA) lies at the
heart of establishing su icient fire prevention,
protection and suppression measures, alongside
safe evacuation procedures to be applied in
the event of an incident. These should include
appropriate COVID-19-related social distancing
measures at any evacuation point to ensure
compliance with ongoing Government guidance
and protect the health and safety of evacuees. Put
simply, LSFRA protects lives and the Duty Holder is
tasked with ensuring it is completed.
Assessment is best conducted when a building
is occupied and operational since any changes to
the use or occupancy of a building are essential to
consider in any assessment, as is the integrity of
physical elements such as escape routes and fire
doors. Where five or more people are employed
the results of LSFRAs must be documented and any
LSFRAs must also be periodically reviewed to ensure
they remain valid, for example when any change of
use is implemented.
WHO IS THE ‘DUTY HOLDER’?
At first sight this may appear straightforward. Yet
when it comes to premises with complex contractual
arrangements such as private finance initiatives
(PFIs), it’s not always so clear. The Duty Holder can
be anyone with control and/or oversight of the
premises, such as a facilities or estate manager, or
14 APRIL 2021
it could be the owner, the landlord, or occupier(s).
In most instances it is considered the responsibility
of each employer to safeguard their employees,
students and visitors. The Duty Holder has to work
together with all other parties, such as the facilities
management provider or assigned contractor, to
ensure the requirements of the LSFRA are met.
If the maintenance of the building (including
regular fire alarm testing, portable fire extinguishers
and other routine maintenance issues) is
undertaken by the facilities management provider,
and/or other contractors, the Duty Holder must, in
order to fulfil their duty, maintain a close working
relationship with all the providers, to ensure the
required maintenance procedures are being carried
out, and that changes in use are reflected in the
siting and maintenance of safety equipment.
COMPETENCY CONSIDERATIONS
Mindful of the potential for overburdening
organisations, UK legislation does not currently
define fire risk assessor ‘competence’. Government
guidance advises that where Duty Holders feel
unable to complete a fire risk assessment they
should seek the advice of a competent person. The
guidance recommends assessments be conducted
by a person with comprehensive training and
experience in the type of fire risk assessment they
are being asked to carry out.
Third Party Certification adds significant
assurance and rigour for Duty Holders looking for a
In association with
provider to help them meet fire safety obligations; it
demonstrates to Duty Holders the professionalism
and competency of LSFRA companies which
invest in an
independent,
on-going audit
programme
looking at their
operations.
Organisations
holding
Third Party
Certification
as evidence of
competence to
conduct fire risk
assessments
demonstrate
their services are in line with relevant fire safety
legislation, current Codes of Practice, national
guidance and best practice.
Organisations with responsibility for large
numbers of people may consider independently
assessed competence of contractors providing fire
risk assessment a much preferable alternative to the
self-declared capability of an individual assessor.
This is all the more true in challenging environments
such as hospitals, residential care premises, large
shopping complexes and other facilities where
occupancy profile and/or on-site processes may
necessitate a complex or delayed fire evacuation
strategy.
Following the 2017 Grenfell fire, the Independent
Review of Building Regulations and Fire Safety by
Dame Judith Hackitt – which reported the following
year – emphasised the responsibilities of the person
appointed for fire safety within a building and the
actions they can take to mitigate fire risk.
CONCLUSION
Ensuring all appropriate fire safety measures are
competently identified by risk assessment and
e ectively implemented remains a key task in
workplaces reopening in line with the easing of
government restrictions and safe working guidelines
across the four nations of the UK.
Calling on Third Party Certificated LSFRA providers
to review measures in place can help Duty Holders
ensure they have their fire safety bases covered.