What Happens If a FRAEW Identifies High Risk?

A Fire Risk Appraisal of External Walls (FRAEW) carried out in accordance with PAS 9980:2022 is a structured, risk-based assessment of the fire performance of a building’s external wall systems.

One of the most common concerns building owners and Responsible Persons have is: What happens if the FRAEW identifies a high or elevated fire risk?

The short answer is: it does not automatically mean wholesale cladding removal — but it does mean proportionate action is required.

This guide explains what a “high risk” outcome means under PAS 9980, what steps typically follow, and how Responsible Persons should respond in a legally defensible way.

Understanding What “High Risk” Means Under PAS 9980

PAS 9980 does not operate as a pass/fail compliance test.

Instead, it requires assessors to consider:

• The probability of fire spread via the external wall system
• The potential consequences for occupants

Where both probability and consequence are significant, the assessor may conclude that the external wall system presents an elevated or high life safety risk.

PAS 9980 requires assessors to evaluate façade fire spread risk in the context of the building’s evacuation strategy (e.g. stay-put or simultaneous evacuation), compartmentation reliability and occupant vulnerability.

A high-risk finding under PAS 9980 typically indicates that one or more of the following risk factors are present:

• Combustible materials are present in a configuration that could support rapid fire spread
• Cavity barriers or fire stopping may be inadequate or compromised
• The building’s evacuation strategy relies heavily on compartmentation that could be undermined by façade fire spread
• The consequences of fire spread (e.g. high-rise occupancy) increase life safety impact

Importantly, PAS 9980 supports proportionate decision-making. A high-risk finding does not automatically mandate full façade replacement or imply immediate structural failure; it reflects the combined assessment of likelihood and life safety consequence in the specific building context.

Assessors may also consider intended fire performance benchmarks referenced in Approved Document B.

Immediate Steps After a High-Risk FRAEW Outcome

When a FRAEW identifies high risk, the Responsible Person should:

1. Formally record the findings
2. Review the building’s fire risk assessment
3. Consider interim control measures
4. Develop a proportionate action plan

External wall fire risk sits within the scope of fire safety legislation following clarification under the Fire Safety Act 2021. That means the Responsible Person must ensure risks are identified and managed so far as is reasonably practicable.

This sits within the wider duties imposed by the Regulatory Reform (Fire Safety) Order 2005, which requires Responsible Persons to manage fire risk so far as is reasonably practicable.

The key word is managed.

This does not require immediate evacuation in most cases, but it does require demonstrable action and documented professional reasoning.

Interim Measures: What May Be Required?

Before any major remediation is undertaken, interim measures may be necessary to reduce immediate risk.

These can include:

• Reviewing evacuation strategy (e.g. moving from stay-put to simultaneous evacuation where justified)
• Installing temporary fire alarm systems
• Increasing fire safety management and inspections
• Removing combustible materials from balconies where appropriate
• Improving compartmentation defects internally

Interim measures are not a substitute for long-term solutions, but they can reduce life safety risk while further investigation or remediation planning is underway.

The correct measures depend entirely on the specific risk profile identified in the FRAEW.

Does High Risk Always Mean Remediation?

Not necessarily.

PAS 9980 promotes a proportionate approach. A high-risk conclusion may lead to:

• Targeted remediation (e.g. replacement of specific materials)
• Upgrading cavity barriers
• Removing or altering balcony materials
• Limited façade intervention rather than full removal

Full system replacement tends to be considered where:

• Combustible cladding systems are extensive
• There is clear evidence of poor fire performance configuration
• The risk cannot be reasonably mitigated through management or partial works

Every decision should be supported by evidence and documented professional judgement.

Further Investigation May Be Required

In some cases, a high-risk finding arises due to uncertainty rather than confirmed performance failure.

Where documentation is incomplete or materials cannot be confidently verified, further intrusive investigation or testing may be recommended before remediation decisions are finalised.

This staged approach helps avoid unnecessary works while still addressing genuine life safety concerns.

Integration Into the Fire Risk Assessment

If a FRAEW identifies high risk, the building’s fire risk assessment must reflect that reality.

This may affect:

• Assumptions about compartmentation
• Evacuation strategy
• Action plans and review intervals
• Prioritisation of remedial works

The FRAEW does not replace the fire risk assessment — it informs it and should be integrated into the wider fire risk assessment strategy.

Failing to integrate the findings properly could expose the Responsible Person to regulatory scrutiny.

Regulatory and Funding Implications

A high-risk FRAEW outcome may trigger:

• Engagement with enforcing authorities
• Lender enquiries
• Insurer review
• Eligibility considerations for remediation funding schemes

In such cases, clear documentation and proportionate professional advice are critical.

Well-structured reporting supports defensible decision-making and demonstrates that the Responsible Person is acting responsibly and lawfully.

In some cases, a high-risk FRAEW may form part of evidence required for remediation funding applications or regulatory engagement.

Managing Risk vs Creating Panic

One of the biggest misconceptions is that a “high risk” FRAEW means immediate evacuation or catastrophic failure.

In reality, the appraisal process is designed to:

• Clarify risk
• Quantify consequences
• Support rational decision-making

Buildings rarely move directly from appraisal to extreme measures without staged assessment and proportionality.

Competent professional guidance is essential to avoid overreaction or unnecessary expenditure.

A FRAEW should not be confused with an EWS1 assessment, which serves a different purpose in property transactions.

How We Support Clients Following a High-Risk FRAEW

At Fire Risk Assessment Network, our role does not end with issuing a report.

Where elevated or high risk is identified, we support Responsible Persons by:

• Explaining findings clearly in plain English
• Advising on proportionate interim measures
• Assisting with integration into the wider fire risk assessment
• Supporting prioritised remediation planning
• Providing defensible documentation for regulatory review

Our objective is clarity and proportionality — not automatic remediation assumptions.

If you have received a FRAEW identifying elevated or high risk and need support understanding the next steps, we can provide structured, practical guidance tailored to your building.

Conclusion

If a FRAEW identifies high risk, it signals that the external wall system presents a life safety concern that must be addressed — but it does not automatically mandate full cladding removal.

The appropriate response typically involves:

• Careful documentation
• Proportionate interim measures
• Integration into the fire risk assessment
• Targeted remediation planning

PAS 9980 is designed to support evidence-based decision-making. With competent professional input, high-risk findings can be managed methodically and responsibly.

For Responsible Persons, freeholders and managing agents, the focus should be on structured risk control — not panic — and on ensuring that decisions are proportionate, defensible and aligned with current fire safety guidance.

Frequently Asked Questions

What does a high-risk FRAEW mean?

A high-risk FRAEW means the external wall system presents a significant life safety concern based on the probability of fire spread and the potential consequences for occupants. It indicates that proportionate action is required, but it does not automatically mandate full cladding removal.

Does a high-risk FRAEW mean the building is unsafe?

Not necessarily. It means that façade fire risk requires mitigation or remediation. Interim control measures may reduce risk while longer-term solutions are planned. The outcome must be integrated into the building’s fire risk management strategy.

Does high risk automatically require cladding removal?

No. PAS 9980 promotes proportionate, evidence-based remediation. In some cases, targeted intervention or improved fire safety management may be sufficient. Full façade replacement is only justified where risk cannot reasonably be mitigated.

What interim measures might be required?

Interim measures can include reviewing evacuation strategy, installing temporary fire alarm systems, removing combustible balcony materials, increasing inspections, or improving internal compartmentation. The specific measures depend on the building’s risk profile.

Who is responsible for acting on a high-risk FRAEW?

The Responsible Person under the Fire Safety Order is legally accountable for ensuring that fire risks are properly managed. Decisions should be supported by competent professional advice and clearly documented.

Can a high-risk rating change after further investigation?

Yes. If additional intrusive investigation or testing clarifies the façade construction and reduces uncertainty, the risk conclusion may change. PAS 9980 supports staged investigation to ensure proportionate outcomes.