The duty to carry out a Fire Risk Assessment in the communal areas of a residential block or property falls under The Regulatory Reform (Fire Safety) Order 2005.
This is because communal areas of managed residential property are rightly considered as non-domestic premises and consequently attract the requirements of The Order. In terms of assessment frequency, the guidance is somewhat vague with no specified time periods for how often Fire Risk Assessments must be reviewed, only that it should be regular. In general, Fire Risk Assessments will usually need to be reviewed every 1-3 years; our recommendations are given at the discretion of the Risk Assessor and ordinarily based upon the type of property, its management processes and the severity of the risks found at the property.
The Fire Risk Assessment is considered as being the best entry point for fire management of an existing property because the Risk Assessment forms the ‘Check’ element of the Plan, Do, Check, Act cycle of continuous improvement.
In this article, we discuss some of the crucial points that Fire Risk Advisors look for when carrying out a Fire Risk Assessment on a residential block, as well as discussing when a Fire Risk Assessment may need to go beyond the communal areas and become more intrusive.
What are Risk Assessors looking for when they carry out a Fire Risk Assessment?
Communal-area only (aka. Type 1) Fire Risk Assessments will review the common parts of a block of flats and will identify the fire hazards and risks in the building. As well as the slightly more self-evident hazards, such as the storage of combustible items on escape routes, they will also look for any process issues, such as inspection regimes and routine tests; these are referred to as legal non-compliances.
For instance, they will check for records of:
- Fire Door Inspections
- Inspection and maintenance of fire detection and alarm systems
- Fixed electrical installation inspections
- Testing and maintenance of emergency lighting
- Frequency and sufficiency of property inspections
- Means of escape
In addition to this, the Assessor will be looking for evidence of co-ordination, co-operation and communication with residents, regarding;
- Their individual flat entrance doors.
- Any neighbouring commercial units
- Fire safety within non communal areas.
- The emergency plan for the property.
These lists are not exhaustive and will of course differ with every property. Should you require further information to prepare for a forthcoming Risk Assessment then please feel free to give our team a call.
Are resident’s entrance doors considered in Fire Risk Assessments?
Such doors often form a vital part of the escape route, plugging the one necessary gap – the flat entrance – in an otherwise perfectly sealed compartment where any fire would theoretically be contained for a known minimum period of time. Therefore, the condition and adequacy of the resident’s entrance doors form a vital element of your Fire Risk Assessment.
In a leaseholder owned environment, it is not always simple, or indeed possible, to gain access to inspect the residents entrance doors, although every effort should be made to ascertain the condition of these doors. It can – and should – be done, but priority should be given to access those that are showing clear signs of being insufficient when viewed from the outside, such as;
- Any damaged doors
- Blocks containing multiple visually different entrance doors
- Any UPVC doors
- Doors or door-frames with clear gaps through to the flat behind them
- Any door furniture (handles, locks knockers or letterboxes) that have been added retrospectively
- Any glazing on or around the door that does not appear to be fire rated
Fire Door and Installation certificates will be available for flats in relatively new buildings, but even these doors should still be inspected regularly to ensure that they have not been altered in any way (self-closers removed, letterbox cut in, smoke seals not painted over etc.) and are still operating correctly (closing fully into their frame, self-closer operating adequately etc.).
Importantly, such certificates of installation are not an absolute requirement, but do help to know that you are working from a good starting point. Indeed, in the case of older buildings, they would be almost impossible to obtain retrospectively. A notional Fire Door is a fire door that will theoretically perform adequately in the event of a fire, albeit it hasn’t been originally designed or tested to do so. As an example, you may have a listed building containing original large solid oak doors that have had smoke seals and self-closers retrospectively fitted in order to achieve 30-minute protection and comply with any historical conservation restrictions.
A good Fire Risk Assessor and Fire Door inspector should be able to identify any concerns in a clear and concise report, recommending any actions that need taking in order to improve the adequacy of your resident’s Fire Doors.
Compartmentation Surveys / Intrusive Fire Risk Assessments
A Fire Risk Assessment of the communal area only (aka. Type 1) is the most common type of Fire Risk Assessment and is usually sufficient for most purpose-built blocks of flats and also for some conversions. Type 1 is a non-destructive assessment of the communal areas of the building, not including the private dwellings.
A positive assumption must be made that the building was constructed or converted adequately to building regulations at the time of construction; therefore, an assessment of the occupied areas is not expected, or required, unless there is there is reason to believe that there may be significant issues inside the flats or if there are communal service shafts running between units.
If there is any evidence to the contrary of this positive assumption – such as defects indicating questionable construction methods or works that may be suspected of damaging the compartmentation – an intrusive Fire Risk Assessment may be required. These Fire Risk Assessments review the construction and substructure of the building, often including the areas inside the flats, resulting in a definitive evaluation of any defects that are likely to negatively impact how the building might behave in the event of a Fire.
A Compartmentation Survey often tends to be intrusive in nature and so it involves an element of destructive inspection. When carried out unnecessarily, or without good reason, they can often create more risk than they resolve; this is because the intrusive nature will often necessitate the need to breach an otherwise perfect compartment in order to complete the inspection adequately. A reputable Risk Assessor will implement temporary repairs to ensure that this risk is mitigated while a repairs contractor is mobilised, but the risk will always be heightened for that short period of time. There is also the risk of Asbestos to be considered in older buildings, where Asbestos Insulation Boarding is likely to have been used for its fire-retardant qualities as compartmentation.
Generally, Compartmentation Surveys are only necessary in a very limited range of circumstances and not be routinely recommended unless there is strong justification. For instance, a Compartmentation Survey may be recommended if a new landlord has acquired a block of flats for which the history of construction work is unknown and there appear to be multiple breaches in compartmentation noted by the general Fire Risk Assessment for the common parts. Furthermore, they may also be required in light of an enforcement notice issued to the building.
