If you are a Responsible Person under the Regulatory Reform (Fire Safety) Order 2005, or if you are trying to understand what a fire risk assessment actually involves, you may have come across references to the five steps of a fire risk assessment.
The five-step framework is the approach recommended by the UK Government and the Health and Safety Executive for carrying out fire risk assessments, and it provides a structured and logical way of working through the assessment process.
This article explains what the five steps are, what each one involves, and why each one matters.
Where Does the Five-Step Framework Come From?
The five-step framework for fire risk assessments is set out in the Government’s fire safety guidance documents published under the Regulatory Reform (Fire Safety) Order 2005 (SI 2005/1541).
The RRO requires the Responsible Person to carry out a suitable and sufficient fire risk assessment, but it does not prescribe a specific methodology for doing so.
The five-step framework is the Government’s recommended approach for meeting that requirement, and it is widely used by fire risk assessors, employers, and building managers across England and Wales as the standard methodology for structuring and documenting the assessment process.
The framework draws on the same principles as the general risk assessment approach recommended by the Health and Safety Executive under the Management of Health and Safety at Work Regulations 1999 (SI 1999/3242), adapted specifically for fire safety.
Understanding the five steps helps Responsible Persons to engage more meaningfully with their fire risk assessment, to understand what the assessor has done and why, and to take an active role in managing the findings and actions that result from the assessment.
Step One: Identify Fire Hazards
The first step of the fire risk assessment is to identify all of the fire hazards present in the premises.
A fire hazard is anything that has the potential to cause a fire or to make a fire worse.
There are three components to a fire hazard, and all three must be present for a fire to start and develop.
The first is an ignition source, something that can start a fire.
Ignition sources in workplaces and residential buildings include electrical equipment and electrical faults, cooking equipment and cooking processes, heating equipment, smoking materials, candles and naked flames, hot works such as welding, cutting, and brazing, lightning strikes, and arson.
The second is fuel, something that can burn.
Fuel sources in most premises are plentiful and varied, including paper and cardboard, textiles and upholstered furniture, wood and timber, plastics, packaging materials, flammable liquids such as solvents and cleaning products, gases including LPG and natural gas, and the building fabric itself including wall linings, floor coverings, and roof materials.
The third is oxygen, which in most premises is provided by the air.
Areas with enhanced oxygen levels, such as rooms where oxygen therapy is used in healthcare settings, present a particularly elevated fire risk because fires ignite more easily and burn more intensely in oxygen-enriched atmospheres.
The fire risk assessor will walk through the premises systematically, identifying all ignition sources, all significant fuel sources, and any areas where oxygen enrichment could occur.
The aim of this step is not to list every conceivable hazard but to identify the significant hazards that could realistically cause a fire in the specific premises being assessed.
Step Two: Identify People at Risk
The second step is to identify all of the people who are at risk in the event of a fire.
This means identifying everyone who uses or occupies the premises, or who may be affected by a fire, including employees, customers, visitors, contractors, residents, and members of the public.
Importantly, the assessment must specifically identify any individuals or groups who may be at particular risk because of their characteristics or their location within the premises.
People who work alone or in isolated areas may not hear the alarm or receive assistance to evacuate in time.
Those who work in areas of high fire risk, such as kitchens, plant rooms, or areas where flammable materials are stored, face an elevated risk of being close to a fire when it starts.
People who sleep on the premises, including residents of residential buildings, hotel guests, and anyone sleeping overnight in a workplace, have less time to react and are more vulnerable than those who are awake and alert.
People with mobility impairments may not be able to use standard escape routes or may require assistance to evacuate.
People with sensory impairments, including visual or hearing impairments, may not be able to detect or respond to a fire alarm in the same way as other occupants.
People with cognitive impairments, including dementia or learning disabilities, may find it difficult to understand and respond appropriately to an emergency situation.
Children and young people may respond differently to adults in an emergency and may require specific guidance and assistance.
Visitors and members of the public are often unfamiliar with the building and its escape routes, and may need clear direction during an evacuation.
And lone workers or occupants in remote parts of a large building may not receive timely assistance if they encounter difficulty during an evacuation.
The identification of people at particular risk is essential for ensuring that the fire safety measures and evacuation arrangements address the specific needs of all occupants.
Where individuals who may need assistance to evacuate are identified, Personal Emergency Evacuation Plans must be developed for each of them, setting out the specific arrangements for their evacuation and the responsibilities of named individuals for assisting them.
Step Three: Evaluate, Remove, Reduce, and Protect Against the Risk
The third step is the analytical heart of the fire risk assessment, and it is the step that requires the greatest level of professional judgement and expertise.
It involves evaluating the risk to the people identified in step two from the hazards identified in step one, and then identifying and implementing measures to remove or reduce those risks to an acceptable level.
The evaluation of risk must consider both the likelihood of a fire occurring and the potential consequences of a fire for the people at risk.
A hazard that is highly likely to result in a fire, such as a damaged electrical installation or a poorly managed deep fat fryer, combined with a high consequence scenario, such as occupants who are asleep or who cannot self-evacuate, represents a very high level of risk that demands urgent action.
A hazard that is unlikely to result in a fire, combined with a scenario where the consequences would be limited, may represent an acceptable level of risk that can be managed through routine maintenance and monitoring.
The evaluation must consider the fire safety measures already in place, including passive measures such as compartmentation, fire doors, and fire-resisting construction, active measures such as fire detection and alarm systems, suppression systems, and emergency lighting, and management measures such as fire safety training, evacuation procedures, and hot works management.
The assessor must judge whether the existing measures are adequate to reduce the risk to an acceptable level, or whether additional measures are needed.
Where additional measures are needed, they should be identified and prioritised in accordance with a hierarchy of controls.
The preferred approach is to remove the hazard entirely, by eliminating ignition sources, reducing fuel loads, or substituting hazardous materials or processes with safer alternatives.
Where the hazard cannot be removed, the next step is to reduce it as far as reasonably practicable, by improving maintenance, upgrading electrical installations, managing fuel loads, or implementing better controls on high-risk activities.
Where the risk cannot be fully removed or reduced through hazard management, protective measures must be implemented to limit the consequences of a fire, including improving compartmentation, upgrading fire detection and alarm systems, installing suppression systems, improving means of escape, and enhancing evacuation procedures.
The third step also considers the two fundamental questions that underpin the ASET and RSET analysis discussed in our earlier article.
How long do occupants have to escape before conditions become untenable, and how long does it actually take for all occupants to reach a place of safety?
If the time available for escape is not sufficient for all occupants to reach safety, the fire safety measures must be improved either to increase the available time or to reduce the time required for evacuation.
Step Four: Record, Plan, Inform, Instruct, and Train
The fourth step involves documenting the findings of the assessment, developing an action plan, and ensuring that all relevant information, instructions, and training are provided to those who need them.
For premises where five or more people are employed, the significant findings of the fire risk assessment must be recorded in writing under Article 9 of the RRO.
Even for smaller premises where written recording is not a legal requirement, it is strongly advisable as evidence of compliance and as a basis for managing the findings of the assessment over time.
The written record should include a description of the premises and its occupancy, the significant hazards identified in step one, the people at particular risk identified in step two, the evaluation of risk and the fire safety measures currently in place, the additional measures required and the priority order in which they should be implemented, and any other relevant findings or observations.
The action plan should set out each remedial action required, the person responsible for implementing it, the target date for completion, and the priority level of the action based on the level of risk it addresses.
Urgent actions, addressing significant and immediate risks to life safety, must be implemented without delay.
Lower-priority actions can be scheduled within a reasonable timeframe, but must not be indefinitely deferred.
The action plan must be actively managed, with progress monitored and recorded, and the fire risk assessment updated to reflect actions as they are completed.
Alongside the written record, step four requires the Responsible Person to ensure that all relevant people are informed, instructed, and trained.
Under Article 21 of the RRO, employees must receive adequate fire safety training, including instruction in the emergency procedures, training in the use of firefighting equipment where appropriate, and practical fire evacuation drills at appropriate intervals.
Residents of residential buildings must be provided with fire safety information under the requirements of the Fire Safety (England) Regulations 2022 (SI 2022/547), including information about the building’s evacuation strategy, the actions to take in the event of a fire, and the importance of maintaining fire safety measures such as fire doors.
Contractors must be informed of the fire risks relevant to their work and the emergency procedures in place before they begin work on the premises.
And visitors and members of the public must be given appropriate fire safety information and must be included in the evacuation arrangements.
Staff with specific fire safety responsibilities, including fire wardens, must receive training appropriate to their role, covering their specific duties in the event of a fire, the operation of the fire detection and alarm system, and the procedures for managing the evacuation and accounting for all occupants.
Step Five: Review and Update the Assessment
The fifth and final step is the review and update of the fire risk assessment.
Under Article 9 of the RRO, the Responsible Person is required to review the fire risk assessment regularly and to revise it where it is no longer valid or where there have been significant changes to the premises, the people who use it, or the fire safety measures in place.
The fire risk assessment is not a one-off document.
It is a living document that must reflect the current condition of the premises and its occupancy at all times.
A fire risk assessment that was accurate and comprehensive when it was carried out, but that has not been reviewed or updated since, may have become out of date and may no longer provide an adequate basis for managing fire safety in the premises.
The frequency of review will depend on the nature of the premises, the level of risk, and the rate of change in the premises and its occupancy.
For most premises, an annual review is considered a minimum, with more frequent reviews in higher-risk premises or where changes occur more rapidly.
The assessment must be reviewed and updated whenever significant changes occur that may affect the fire risks or the adequacy of the fire safety measures.
These include alterations to the building, including refurbishment works, changes to the layout, or works that affect the compartmentation or fire protection of the building.
Changes to the use of the premises or the activities carried out within it.
Changes in the number or characteristics of the occupants, including the introduction of a new category of occupant such as a vulnerable group.
Changes to the fire safety systems or measures in place.
The introduction of new ignition sources, fuel loads, or hazardous materials.
Any fire, near miss, or dangerous occurrence that reveals a gap in the existing arrangements.
Any enforcement action or formal advice from the fire and rescue service or other enforcement authority.
And any changes in legislation or guidance that affect the fire safety obligations applicable to the premises.
The review should not simply be a confirmation that nothing has changed.
It should be a genuine reassessment of the fire risks and the adequacy of the measures in place, informed by the experience of managing fire safety in the premises since the last assessment and by any new information or guidance that has become available.
Where the review identifies significant changes in risk or significant deficiencies in the existing measures, the assessment should be revised accordingly and the action plan updated to address the new findings.
Who Should Carry Out the Fire Risk Assessment?
The RRO requires that the fire risk assessment is carried out by a competent person.
A competent person is one with sufficient training, experience, and knowledge to identify and evaluate the fire risks in the premises and to determine the measures needed to address them.
For simple, low-risk premises, it may be possible for the Responsible Person or a member of their staff to carry out the assessment themselves, provided they have the necessary knowledge and competence.
For more complex, higher-risk, or unusual premises, the assessment should be carried out by a professional fire risk assessor with relevant qualifications and experience.
Professional fire risk assessors may be members of recognised bodies such as the Institution of Fire Engineers, the Institute of Fire Safety Managers, or the Fire Risk Assessment Competency Council, and may hold qualifications such as the NEBOSH National Certificate in Fire Safety and Risk Management or the IFE Level 4 Certificate in Fire Safety.
The Third Party Certification schemes operated by bodies such as BAFE provide accreditation for fire risk assessment organisations, giving Responsible Persons assurance that the assessor they are appointing meets recognised competence standards.
Regardless of who carries out the assessment, the Responsible Person retains legal responsibility for ensuring that it is suitable and sufficient and that the findings are acted upon.
We Can Help
At ESI: Fire Safety, we carry out fire risk assessments for premises of all types and sizes, following the five-step framework and applying our professional knowledge and experience to produce assessments that are thorough, compliant, and genuinely useful as a basis for managing fire safety.
We produce clear, practical written reports that identify the significant hazards and risks, document the fire safety measures in place, and set out a prioritised action plan for addressing any deficiencies found.
We work with building owners, employers, landlords, managing agents, and facilities managers to ensure that their fire risk assessments are current, comprehensive, and properly acted upon, and we provide support and advice on all aspects of fire safety management throughout the life of the assessment.
If you need a fire risk assessment for your premises, or if your existing assessment has not been reviewed recently and you are concerned that it may be out of date, get in touch with our team today.
Further Reading and Key Legislation:
Regulatory Reform (Fire Safety) Order 2005 (SI 2005/1541): https://www.legislation.gov.uk/uksi/2005/1541/contents/made
Management of Health and Safety at Work Regulations 1999 (SI 1999/3242): https://www.legislation.gov.uk/uksi/1999/3242/contents/made
Fire Safety (England) Regulations 2022 (SI 2022/547): https://www.legislation.gov.uk/uksi/2022/547/contents/made
Fire Safety Act 2021 (c.24): https://www.legislation.gov.uk/ukpga/2021/24/contents/enacted
Building Safety Act 2022 (c.30): https://www.legislation.gov.uk/ukpga/2022/30/contents/enacted
GOV.UK Fire Risk Assessment guidance: https://www.gov.uk/workplace-fire-safety-your-responsibilities/fire-risk-assessments
HSE Five Steps to Risk Assessment: https://www.hse.gov.uk/simple-health-safety/risk/steps-needed-to-manage-risk.htm
This post is intended as a general guide to the five-step fire risk assessment process. The specific requirements for any individual premises will vary depending on its type, size, occupancy, and risk profile. Always seek advice from a qualified fire risk assessor for guidance specific to your premises and circumstances.
