Fire Risk Assessment for Block Managers

Block managers sit at the operational centre of fire safety compliance in residential buildings. Even where a freeholder, RMC or RTM company is the legal owner, a block manager may be treated as the Responsible Person (or share duties with them) if they control the building’s common parts in practice.

Under the Regulatory Reform (Fire Safety) Order 2005 (the Fire Safety Order), the key legal test is control — not job title. For common or shared areas in multi-occupied residential buildings, government guidance notes the Responsible Person is typically the landlord, freeholder or managing agent. In many blocks, the block manager is the person delivering these duties day-to-day.

This guide explains when a fire risk assessment is required for block managers, what it should cover, and how to reduce legal, financial and reputational risk through structured compliance.

If you need a compliant fire risk assessment anywhere in the UK, contact Fire Risk Assessment Network for a free, no-obligation quotation.

Do Block Managers Need a Fire Risk Assessment?

A fire risk assessment is required wherever the Fire Safety Order applies — and for blocks of flats it applies to the common parts (communal corridors, stairways and other shared areas).

As a block manager, you may not personally “own” the building, but you are often responsible for ensuring a suitable and sufficient assessment exists, is current, and is acted on — because you control (or strongly influence) building safety management in practice.

When Is a Block Manager the Responsible Person?

A block manager is most at risk of being treated as the Responsible Person where they have practical control over the common parts via a management agreement and are the party arranging, instructing or overseeing fire safety measures.

This commonly occurs where the block manager:

• Controls day-to-day management of communal areas (stairs, corridors, entrance lobbies)
• Instructs contractors for fire alarm servicing, emergency lighting, fire doors or remedial works
• Manages building access, housekeeping and fire safety signage
• Maintains compliance records and delivers resident communications

In shared premises, there can be more than one Responsible Person (for example, where commercial units exist below flats). In those cases, duty holders must coordinate and cooperate so the overall fire safety strategy works.

What Parts of the Building Does the Assessment Cover?

For a typical block manager, the fire risk assessment usually covers the common parts, such as:

• Entrance halls and reception/lobby areas
• Corridors, landings and stairwells (escape routes)
• Bin stores, cycle stores and communal rooms
• Plant rooms, risers and service cupboards
• Fire alarm systems, emergency lighting and firefighting equipment (where present)

Buildings Containing Flats: What Changed After 2021?

The Fire Safety Act 2021 clarified that, for buildings containing flats, the scope includes the building structure, external walls (including cladding, balconies etc.) and flat entrance doors (where they are the doors between flats and the common parts). This is particularly important for blocks where fire doors and external wall considerations are part of the risk picture.

(Practically: you don’t need to become a cladding expert — but you do need to ensure the assessment scope is correct and that competent specialists are used where required.)

What Does the Fire Safety Order Require in Practice?

Under Article 8 and Article 9 of the Fire Safety Order, the Responsible Person must take general fire precautions and carry out a suitable and sufficient fire risk assessment.

Where the Fire Safety Order applies, the Responsible Person must carry out a suitable and sufficient fire risk assessment and keep it under review.

These duties are owed to “relevant persons”, which include residents, visitors, contractors and anyone lawfully on the premises.

From a block management perspective, this typically means you need systems in place to ensure:

• The risk assessment exists, is building-specific, and is current
• Actions are prioritised and tracked to completion (with dates and evidence)
• Routine checks and servicing are scheduled and recorded
• Escape routes are kept clear and fire doors are maintained
• Contractors are controlled (permits, fire stopping standards, sign-off evidence)
• Residents receive the required fire safety information (where applicable)

A “paper FRA” that isn’t implemented is one of the fastest routes to enforcement.

Fire Safety (England) Regulations 2022: Key Operational Duties for Block Managers

If you manage multi-occupied residential buildings in England, additional duties apply under the Fire Safety (England) Regulations 2022. These duties typically sit in the block manager’s operational workload (even if the freeholder/RMC/RTM remains the legal duty holder).

Depending on the building, these include:

• Providing residents with clear fire safety instructions based on the building’s evacuation strategy
• Giving residents information about fire doors (for example, keeping doors shut and reporting defects)
• Completing routine checks of communal fire doors
• In certain buildings, completing checks of flat entrance doors
• Keeping records of checks and follow-up actions where required

Because these requirements assume an FRA is in place, your fire risk assessment becomes the foundation for what you communicate, inspect and record.

Mixed-Use Blocks: Extra Coordination Requirements

Where a building has shops, offices or other non-domestic areas below residential floors, responsibilities are commonly split:

• Tenants are typically responsible for their own demised premises
• The building owner / managing agent / block manager is responsible for common parts and shared systems

The key compliance risk is failure to coordinate:

• Alarm cause/effect and testing schedules
• Shared escape routes and final exits
• Fire stopping and penetrations through compartment lines
• Contractor works and permit systems

The Fire Safety Order requires duty holders to cooperate and coordinate to ensure overall fire safety arrangements are effective.

What Happens If a Block Manager Does Not Comply?

If you are the Responsible Person — or are effectively acting as the party in control of fire safety — failure to comply can result in enforcement action.

Breach of the Regulatory Reform (Fire Safety) Order 2005 is a criminal offence. Enforcement action by the local Fire and Rescue Authority may include:

• Alterations Notices
• Enforcement Notices
• Prohibition Notices
• Criminal prosecution and unlimited fines (in serious cases)

Even where the legal duty holder is the freeholder/RMC/RTM, a block manager can face:

• Contractual claims for failure to deliver compliance
• Professional negligence / reputational damage
• Insurer scrutiny after incidents (particularly if records are weak)

How Often Should a Block Manager Review the Fire Risk Assessment?

There is no fixed statutory review interval under the Regulatory Reform (Fire Safety) Order 2005. However, the fire risk assessment must be kept under review and revised where necessary.

Review is required following material alterations, significant occupancy changes, changes to fire safety systems, a fire incident, or where deficiencies indicate existing controls are ineffective.

In practice, review frequency should be risk-based. Higher-risk buildings — such as those with complex layouts, vulnerable residents or external wall concerns — require more frequent re-inspection than lower-risk blocks.

Many residential blocks adopt an annual review cycle as a practical baseline, with more frequent re-inspection for higher-risk buildings and longer intervals for demonstrably low-risk properties.

Block Manager Fire Risk Assessment Compliance Summary

If you manage or control common parts of a building containing flats, you are likely to have duties under the Fire Safety Order — and you may be treated as the Responsible Person depending on control.

A compliant approach means:

• A building-specific FRA with correct scope (including items clarified by the Fire Safety Act 2021)
• Evidence-based action tracking
• Routine checks and maintenance records
• Resident communications and door-check regimes where required in England under the 2022 Regulations

Why Use a Professional Fire Risk Assessor?

Block managers are often judged not only on whether an FRA exists, but on whether it is suitable, current, and implemented.

Common failures that cause enforcement and disputes include:

• Generic assessments copied across blocks
• Fire door defects not tracked or re-checked
• Poor housekeeping and blocked escape routes
• Missing or inconsistent maintenance records
• Weak resident information delivery and record keeping (England Regulations)

A competent assessor provides a defensible baseline and a clear, prioritised plan for your building.

Conclusion

Block managers operate at the frontline of fire safety compliance in residential buildings. While ownership may sit with a freeholder, RMC or RTM company, practical control over the common parts often rests with the block manager. Under the Regulatory Reform (Fire Safety) Order 2005, control — not job title — determines responsibility.

If you manage communal areas, instruct contractors, coordinate maintenance or deliver resident communications, you must ensure that a suitable and sufficient fire risk assessment is in place and actively implemented. The Fire Safety Act 2021 and the Fire Safety (England) Regulations 2022 have strengthened expectations around fire doors, external wall considerations and resident information, increasing scrutiny on managing agents and block managers.

Delegation does not remove accountability. Clear systems, documented oversight and competent fire risk assessments are essential to reducing enforcement, contractual and reputational risk.

At Fire Risk Assessment Network, we support block managers across the UK with structured, building-specific fire risk assessments and clear prioritised action plans.

If you manage a block and require a compliant assessment, speak to our team today.

Frequently Asked Questions

Are block managers legally responsible for fire safety?

Block managers are not automatically the Responsible Person under the Regulatory Reform (Fire Safety) Order 2005. Legal responsibility depends on who has control of the common parts of the building. Where a block manager exercises practical control over communal areas and fire safety arrangements, they may be treated as the Responsible Person or share duties with the building owner.

Does a block manager need to arrange a fire risk assessment?

In most residential blocks containing flats, a fire risk assessment is required for the common parts. Even where the legal duty holder is the freeholder or RMC, block managers are typically responsible for arranging the assessment, implementing actions and maintaining compliance records under the management agreement.

What areas must a fire risk assessment cover in a block of flats?

For residential blocks, the assessment usually covers communal areas such as stairwells, corridors, entrance halls, plant rooms, bin stores and shared systems. Following the Fire Safety Act 2021, scope also includes the building structure, external walls (including cladding systems) and flat entrance doors where they form part of the fire-resisting construction.

Do the Fire Safety (England) Regulations 2022 affect block managers?

Yes. In England, additional duties apply to multi-occupied residential buildings. These include providing residents with fire safety instructions, giving information about fire doors, undertaking routine checks of communal fire doors and, in certain buildings, checking flat entrance doors. Block managers often coordinate and record these duties in practice.

Can a block manager delegate fire safety responsibilities?

Tasks can be delegated to contractors or managing staff, but legal accountability depends on control. If a block manager has authority over building safety management, enforcement authorities will examine who had practical control and decision-making responsibility, not simply what the contract states.

How often should a fire risk assessment be reviewed in a residential block?

There is no fixed statutory interval. However, the assessment must be reviewed where necessary — particularly after material alterations, system changes, significant occupancy changes or a fire incident. Many block managers adopt an annual review cycle as good practice, supported by periodic re-inspection depending on building risk.