So, years after Grenfell. Do we really understand what type of FRA we should be requesting, and why?

The FSO defines and states certain duty holders- one such duty holder is known as the 'Responsible Person' (RP) who is legally obliged to undertake an FRA and review the findings.

A couple of myth busters in this one:

1- The Responsible Person is usually, if highly unlikely to be an 'individual, more the Corporate entity.

2- There is NO legal requirement to carry out an ANNUAL FRA. Despite much commentary to the contrary. There is however the onus on the RP to ensure they are reviewing the FRA and actioning the findings- something which has come as a shock to some.

Article 9 of the FSO gives you the legal speak if you want to fact check me:

https://www.legislation.gov.uk/uksi/2005/1541/article/9

The word used is 'regularly'- no mention of 'annual', however you need to check with insurers and local authorities to determine if they expect annual surveys to be undertaken if working in healthcare governed by CQC they expect annual assessments as do Schools and Teaching Institutions who are regulated by Ofsted or ISI (for Independent schools)

So what sort of fire risk assessments are there? 

Guidance previously issued by the Local Government Association (LGA), and endorsed by the National Fire Chiefs Council (NFCC), outlined four types of FRA that those responsible for fire safety in a purpose-built block of flats may arrange to have undertaken. Some of these are destructive, and all are explained below.

Let's talk numbers:

Type 1 – Common parts only (visual only)  

This is the most common type of fire risk assessment and tends to be sufficient for most purpose-built blocks of flats, as well as conversions. It is the basic FRA for satisfying the requirements stipulated by the FSO and takes the form of a non-destructive inspection of the common parts of the flat building, and not the private dwellings. 

Type 2 – Common parts only (destructive) 

A Type 2 FRA largely resembles a Type 1 FRA in its scope and objectives, except that – as the term above suggests – it entails a degree of destructive inspection, taking the form of sampling. A contractor will normally need to be present for this. 

While this type of fire risk assessment may be suggested following a Type 1 FRA, it should not be recommended as standard procedure. Type 2 FRAs are generally rare, and usually only carried out if there is good reason to think the building may have serious structural deficiencies that could lead to a fire spreading beyond the flat in which it originated. 

Type 3 – Common parts and flats (visual only) 

This type of fire risk assessment encompasses the same work involved in a Type 1 FRA, and like a Type 1 FRA, it is non-destructive in nature. Type 3 FRAs go that bit further in that they consider the flats (demised areas) inside the block, and not just the communal areas. 

Someone undertaking a Type 3 FRA will consider the arrangements for means of escape and fire detection (i.e., smoke alarms) in a sample of the demised areas, in addition to accounting for compartmentation between flats. This type of FRA is generally considered necessary if it is thought that there could be a fire risk inside the flats; however, it can be difficult to arrange in leaseholder flats.

With the recent enhancements to the FSO brought in by Section 156 of the Building Safety Act (in Oct 2003) - which states that RPs must consider 'all risks' and that all FRAs must be recorded, it does raise the question if Type 3 FRAs should now be considered the baseline choice over and above a Type 1. 

Type 4 – Common parts and flats (destructive) 

The scope of work for this type of fire risk assessment is the same as that for a Type 3 FRA, except that it involves some destructive inspection in both the communal areas and the flats, undertaken on a sampling basis. 

It is commonly accepted that a 10% sample of the flats is undertaken. And where possible it should take account of sampling across differing types of flat- such as one bed and two bed, studio flats, differing internal designs, differing levels in the building.

As is the case with a Type 2 FRA, a contractor will generally need to be present for the purpose of 'opening-up' and making good once the inspection is done. 

While Type 4 FRAs are the most comprehensive form of fire risk assessment for blocks of flats, they are also the most complicated, and also the most expensive.

There is also added logistical considerations, having to allow time for communicating to residents, and accessing flats. 

However, with some sensible pre-planning 'voids' can be identified which can speed up the process, and whilst these are destructive, the disruptive element can be minimised with some sensible project management and communication.

Traditionally it was only in limited, exceptional, circumstances that saw a Type 4 FRA carried out; such as when a new landlord was taking over a block of flats where the history of works undertaken was unknown, or where there was reason to suspect residents could be at serious risk from fires in both their own flats and adjoining neighbours’ flats. 

The advent of the Safety Case has seen the Type 4 become more 'standard' for a HRB (those buildings that are 7 storeys+ or 18m+, in England). The sampling of compartmentation and evidence of presenting risks in the demised spaces helps colour in the picture of an holistic visualisation of risk for the Principle Accountable Person (PAP), for the whole building.