Firntec Webinar FRA CPD Q&A - December 2025

Following our final webinar of the year, focused on Fire Risk Assessments (FRAs), we’ve summarised the key questions submitted by our attendees in the blog below. The session covered essential elements of FRAs, including hazard identification, risk evaluation, and effective fire safety measures.

Steven Wilson, Chief Technical Director of Firntec & Ian Chand Head of Fire Risk Assessments, provided the answers, addressing FRA types, common findings, external wall considerations, and compliance requirements.

Make sure to attend our future webinars to put your questions directly to our technical specialists.

What would be considered a reasonable area to sample in a fire risk assessment?  

A reasonable sample depends on the building size, occupancy, and risk. For residential blocks, typical guidance is 20–25% of flats for inspection of occupied areas in Type 3 or 4 FRAs, focusing on representative layouts, construction types, and potential high-risk areas. The assessor should document rationale for the sample chosen. 

Which one of the FRA types is compulsory for high building?

There is no statutory FRA type specifically required for high-rise buildings, but in practice, a full or Type 4 FRA (intrusive/full assessment) is expected due to complexity and risk, often requested or reviewed by the regulator.

Please can you define common parts as Inspecting Officers often enter and comment on issues within risers or other areas that could be considered, not a common area accessible by flat owners etc. 

Common parts include all areas used or shared by more than one resident, including corridors, stairwells, lobbies, risers, plant rooms and bin stores. Within legal and building management frameworks, risers and riser cupboards are typically regarded as common areas as these areas are usually accessed and used by staff and contractors.  

Which type FRA for schools comes under? Type1?  Destructive survey?

For schools, Fire Risk Assessments should not be categorised as Type 1–4, as this terminology is specific to housing scenarios, particularly blocks of flats. Instead, a school should be subject to a Full Fire Risk Assessment, which considers the entire premises rather than just common areas. This assessment is generally visual and non-intrusive, covering all rooms, circulation spaces and relevant facilities, with intrusive or destructive surveys only undertaken where there is a clear and justified need to investigate specific concerns such as potential compartmentation defects.

What additional qualifications and experience would a fire risk assessor need to carry out invasive surveys? 

To carry out invasive fire risk surveys, a Fire Risk Assessor needs advanced fire safety qualifications (e.g., NEBOSH Fire Safety Certificate or Level 5 Diploma) and specialist training in passive fire protection and building construction. They must have practical experience inspecting hidden elements like cavities, risers, and fire stopping, understand compartmentation standards, and be skilled in safe access techniques, confined space awareness, and asbestos precautions. Invasive surveys require a combination of formal training, technical building knowledge, and documented experience beyond standard FRA competence. 

What constitutes Multiple Occupancy? 

Buildings with (2 or more flats), shared escape routes or shared fire risk, such as HMOs, blocks of flats, and sheltered housing.  The defining feature is shared fire risk, not ownership.
 

How often is a fire risk assessment required, and what is the recommended frequency for sheltered housing blocks? 

Review of a fire risk assessment is not necessarily the same as a repeat of the entire fire risk assessment process. If a thorough fire risk assessment has been carried out, a shorter review exercise might be carried out regularly, with a more fundamental new fire risk assessment completed at less regular intervals. The frequency with which fire risk assessments should be reviewed in the absence of any known changes is not defined in the FSO. The date by which a fire risk assessment should be reviewed should be determined as part of the process of carrying out a fire risk assessment. 

The frequency of review should consider the rate with which changes, including those arising from the need for maintenance work, are likely to occur, and the risk to people that might arise from changes. This means that a less frequent review might be acceptable if there is close management control of the common parts, including frequent routine inspections. 

As a general guide for purpose built blocks of flats (Sheltered housing falls under purpose-built blocks) 

• For a low risk, modern, low-rise block (e.g., a block of no more than three storeys above ground, built in the 1960’s), a review every two years might be sufficient, with a new fire risk assessment completed every four years. 
• For blocks with higher risk – arising from social factors, the age of the building, and so forth – and blocks over four storeys in height, an annual review might be more appropriate, with a new fire risk assessment every three years. 
• In extreme cases, for the highest risk premises, an annual fire risk assessment might be appropriate. 

 Non-Housing Example / Triggers for Review: 

You should constantly monitor what you are doing to implement the fire risk assessment to assess how effectively the risk is being controlled. If you have any reason to suspect that your fire risk assessment is no longer valid or there has been a significant change in your premises that has affected your fire precautions, you will need to review your assessment and if necessary, revise it. Reasons for review could include: 

• Changes to work processes or the way that you organise them, including the introduction of new equipment. 
• Alterations to the building, including the internal layout. 
• Substantial changes to furniture and fixings. 
• The introduction, change of use or increase in the storage of hazardous substances.
• The failure of fire precautions, e.g., fire-detection systems and alarm systems, life safety sprinklers, or ventilation systems.
• Significant changes to displays or quantities of stock. 
• A significant increase in the number of people present.
• The presence of people with some form of disability. 

From my understanding, a type 1 FRA would not be sufficient for a special use or public building due to their more complex nature, is that correct?

For special-use or public buildings (such as special use, hospitals, schools, assembly buildings, or other complex non-domestic premises), this terminology is not appropriate. These buildings typically have more complex layouts, varied uses, higher occupant dependency, and more demanding management and evacuation considerations. As such, a Type 1 FRA would not be sufficient. 

In non-housing environments, the correct approach is a Full Fire Risk Assessment, which is bespoke to the building and its use. This assessment considers all relevant areas of the premises, the occupants, fire protection measures, and management arrangements, and may include more detailed inspection where necessary to properly evaluate risk. 

In summary, while a Type 1 FRA is suitable for certain residential settings, special-use and public buildings require a full, building-specific fire risk assessment, rather than reliance on housing-based Type 1–4 classifications. 

Can we type 1 or 3 FRA in line with BS 9792 from now, or is there different applicable date? 

Yes. BS 9792:2025 for housing replaces PAS 79-2:2020 and defines Type 1–4 FRAs. From August 2025, all new housing FRAs should follow BS 9792:2025, including Type 1 and Type 3 assessments. 

Why doesn’t the building safety act apply in Scotland? What impacts does this have on Scottish construction / high rises?

• The Fire (Scotland) Act
• Scottish Building Standards  

While terminology differs, the underlying fire-safety principles remain similar, and Firntec applies equivalent best-practice standards when working in Scotland. 

Does it have typical valid period for different types of extinguishers?

Yes, different types of fire extinguishers have different recommended service and replacement periods. In the UK, fire extinguishers must be serviced annually by a qualified professional in accordance with British Standard BS 5306.  

The primary difference in maintenance schedules relates to the extended service intervals:  

• Water, Foam, Powder, and Wet Chemical extinguishers generally require a basic service every 12 months and extended service (which often involves a test discharge, internal inspection, and refill or unit exchange) every 5 years. 
• CO2 extinguishers require an overhaul and hydrostatic pressure testing every 10 years due to the high pressure they contain.  

While these are the required servicing intervals, the actual total lifespan with proper maintenance can be 10-12 years for most types, and some can last up to 20 years, but they are often replaced at the 5 or 10-year mark as it can be more cost-effective than testing and refilling. 

How much detail would you expect a Fire Risk Assessor to note as an action to replace a damaged fire door? E.g. would you expect the assessor to note "Install a certified BM Trada FD30(s) door and frame" (30min fire door and frame with smoke seal) 

An FRA action should clearly define the work needed without being a full specification. For a damaged fire door, a typical note would be: “Replace damaged door with a 30-minute fire-resisting door and frame, including smoke seals and a self-closing device, ensuring correct installation.” Specifying a brand or certification (e.g., BM Trada) is optional; the key is that the replacement meets the required fire-resistance standards. 

Is this External Wall FRA mandatory in all residential buildings, including Low Rise buildings? 

In the UK, all multi-occupied residential buildings, including low-rise properties, must have a Fire Risk Assessment (FRA) that covers the external walls. However, a more detailed External Wall Fire Risk Appraisal (FRAEW) using the PAS 9980 methodology is only necessary when a competent fire risk assessor identifies a potentially significant risk.  

Can PAS 9980 be applied to other types of buildings? If not, what should be used in its place? 

No. PAS 9980 is specifically for any residential building with 2 or more flats. For other building types (schools, offices, hospitals), use BS 9991/BS 9999, Approved Document B, or other sector-specific fire safety standards. 

When completing an FRA for a children's home, what would the assessor need to know about the children living there and the staff team working there, if FRAs are to be more person centred? 

For a children’s home, a person-centred FRA requires the assessor to understand the needs of the children and the capability of the staff, as evacuation depends heavily on people. This includes the children’s ages, numbers, sleeping arrangements, level of  independence, disabilities or additional needs, behavioural or trauma-related responses, medication effects, and whether they can self-evacuate or may resist or hide. The assessor should also consider night-time supervision, security measures, and any fire-setting behaviours. For staff, key factors are staffing levels (day and night), training and confidence in evacuation procedures, familiarity with the children, use of agency staff, and shift handovers. This ensures the FRA reflects how fire safety will work in practice, not just in theory. 

Who is qualified to carry out a specialised FRAEW survey—does it have to be a fire engineer, a chartered surveyor, or can it be a Level 3 fire risk assessor? 

A Fire Risk Assessment of External Walls (FRAEW) is a specialised survey, but it is not compulsory for it to be carried out solely by a fire engineer or a chartered surveyor. It can be conducted by a competent fire risk assessor, surveyor, or fire safety professional with the appropriate experience and qualifications, typically Level 3 fire risk assessor competence or equivalent, who has the skills and knowledge to assess external wall fire risks in line with the relevant methodology. The critical requirement is demonstrable competence, not a specific professional title. 

How long do you get to complete your FRA recommendations? 

Once a fire risk assessment is completed, any recommendations to reduce risk should be acted on “within a reasonable timescale”. 

• High-risk issues (immediate danger): Should be addressed immediately. 
• Medium-risk issues: Usually within weeks to a few months, depending on resources. 
• Low risk / long-term improvements: Can be planned into a longer-term schedule but still needs documented timelines. 

Legally, you must document when each action will be completed and keep a record showing that the recommendations are being implemented. There’s no fixed statutory number of days, but regulators expect timely action proportional to the risk. 

Can a type 4 give you the same level of assurances about a building's compartmentation as a compartmentation survey? 

No, a Type 4 FRA cannot provide the same assurance as a dedicated compartmentation survey. While it may identify obvious defects, a Type 4 focuses on overall fire risk, not detailed verification of fire-resisting walls, floors, doors, penetrations, or cavity barriers, which a compartmentation survey specifically inspects and documents. 

How old of a building will require a FRAEW? 

An FRAEW (Fire Risk Appraisal of External Walls) is not strictly a legal requirement based on a building's age alone, but is triggered by the type of construction, specifically the presence of potentially combustible external wall materials, or if a competent fire risk assessor has concerns. It applies to multi-occupied residential buildings of any age if these risk factors are present.  

If a PCFRA is complete on someone and let's say they are classed as disabled. Would this then change regs? Like leaving a door closer off a flat entrance fire door? or would this need to be changed to an automatic door to stay within regs? 

Carrying out a person-centred fire risk assessment (PCFRA) for a disabled resident does not automatically change the statutory fire safety requirements. The legal duties under the Building Regulations, Fire Safety Order, and relevant Approved Documents remain. For example: 

• Flat entrance fire doors must meet the required FD30/FD60 rating, be fitted with self-closing devices, and be properly maintained. Removing a door closer would not comply with regulations, even for a disabled resident. 
• A PCFRA may identify that a resident cannot easily operate a standard self-closing door, but the solution is usually to install an automatic or assisted-opening device (like an electro-magnetic hold-open linked to the fire alarm) that maintains fire safety compliance while accommodating the resident’s needs. 
• Any modification must ensure the door still provides the required fire resistance and self-closing function in a fire. Simply leaving the closer off would create a non-compliance and serious fire risk. 

In short, a PCFRA informs reasonable adjustments for accessibility or assisted evacuation, but these adjustments must not compromise the door’s fire-resisting function, usually requiring an automatic door or alarm-linked hold-open device rather than removing the closer. Although this example relates specifically to fire doors, it helps illustrate the priority order between regulations and PCFRAs. 

Since the act has been in place has there been any change in the way FRA is completed or should be completed? is there specific FRA's required for high buildings submitted to regulator? 

Since the introduction of the Fire Safety Order 2005, the legal duty to carry out a Fire Risk Assessment (FRA) has not changed. However, expectations around how FRAs are completed, evidenced, and used have evolved significantly, particularly following the Grenfell Tower tragedy and the introduction of the Building Safety Act 2022. 

For higher-risk buildings, there is no statutory requirement to submit an FRA as a standalone document to the Building Safety Regulator. That said, an FRA is a fundamental component of the Building Safety Case and is relied upon to demonstrate how fire risks are identified, assessed, and controlled. The regulator expects FRAs for these buildings to be more detailed, clearly documented, and regularly reviewed, covering areas such as evacuation strategy, compartmentation, fire safety systems, management controls, and resident risk. 

What is a reasonable time to repair a damaged flat entrance fire door and a communal fire door? 

According to the Fire Safety (England) Regulations 2022 – Fire Door Guidance (gov.uk), there is no fixed timeframe for repairing a damaged flat entrance or communal fire door; the work must be carried out “as soon as reasonably practicable” by a competent contractor. What is reasonable depends on factors such as the risk to residents, the severity of the damage, the availability of a contractor, and access arrangements. Doors that significantly affect fire safety should therefore be repaired or replaced promptly, typically within days to a few weeks, to maintain their protective function. 

With the gaps around fire doors, what type of tolerance would you use or do you work rigidly to the 2-4mm gaps etc? 

The 2-4mm gap is a strict maximum limit, not just a casual tolerance. Adhering to this range is a critical safety requirement derived from the fire door's specific test evidence and certification. Gaps outside this range (specifically, more than 4mm) compromise the door's fire resistance and smoke control performance.  This is the case unless there is specific test evidence to highlight that the door would act in the same way with a 5mm gap as an example, but it is somewhat unusual for door manufacturers to test outside of standard tolerances. 

For a 9m high building, is it compulsory the bin store is upgraded to FD30 even if the nominal door is very much still, okay? 

For a 9 m high building, a bin store does not need its door upgraded if an existing nominal 30-minute fire door is in place and compliant (44 mm thick, correct gaps, self-closing, all hardware in working order). A nominal fire door meets the functional requirements even without a certification label, so replacement is only needed if it fails these standards. 

What steps can you take if you do not have the manufacturer and installation documents to certify they are fire doors? 

If manufacturer or installation documents are unavailable, take the following steps: 

• Visual Inspection – Check key fire-resistance features: certification labels or plugs, intumescent seals, self-closing devices, and correct gaps (typically 2–4 mm). 
• Record Findings – Document observations, noting any missing features or uncertainty about compliance. 
• Third-Party Assessment – If the rating cannot be confirmed visually, commission a competent third-party survey to verify compliance and advise on remedial actions. 
• Destructive Testing (Last Resort) – Only used if essential to confirm fire resistance. 
• Plan for Replacement – If compliance remains uncertain, schedule replacement with a certified FD30 or FD60 door and frame installed by a competent contractor. 
• Document Rationale and Actions – Keep a clear record of inspections, decisions, and any remedial work to demonstrate due diligence. 

BS 9991:2015 and 2024 states that travel distance can be extended so long as there is ventilation and sprinkler system installed, minimum Category 2. My question is, no document states exactly where the sprinkler should be installed. Is it within the flat or in the flat lobby/corridor? 

Travel distance can be extended if a Category 2 sprinkler system is installed. Guidance does not specify exact location, but sprinklers should cover escape routes, usually in flat lobbies/corridors as well as individual flats, so that common escape paths are protected in line with the extended distance provisions. 

Firntec provides Fire Risk Assessments for residential, education, healthcare and commercial buildings. Costs vary depending on building size, complexity, occupancy type and the level of assessment required (Type 1–4, FRAEW, PAS 9980). If you would like a specific quote, then fill out our contact form with as much detail as possible and one of our team will get back to you.