Fire Risk Assessment for Facilities Managers

Facilities managers in the UK often sit at the operational centre of fire safety compliance within commercial, industrial and mixed-use buildings. While the legal duty under the Regulatory Reform (Fire Safety) Order 2005 rests with the “Responsible Person”, facilities managers are frequently the individuals delivering fire safety management in practice.

Where you control day-to-day building operations, oversee maintenance contractors, manage safety systems or employ staff within the premises, you may be treated as the Responsible Person — or share duties with your employer or landlord.

This guide explains when a fire risk assessment is required, how responsibility is allocated in commercial buildings, and what facilities managers must have in place to remain compliant.

If you require a compliant fire risk assessment anywhere in the UK, contact us for a free, no-obligation quotation.

Do Facilities Managers Need a Fire Risk Assessment?

A fire risk assessment is required wherever the Fire Safety Order applies. This includes almost all non-domestic premises, such as:

• Office buildings
• Retail units and shopping centres
• Warehouses and industrial premises
• Hotels and hospitality venues
• Care homes and healthcare premises
• Mixed-use buildings

If you manage these premises, you must ensure a suitable and sufficient fire risk assessment is in place and kept under review.

The key legal test is control. If you control the premises — or control the common parts — you may carry legal duties under fire safety legislation.

When Is a Facilities Manager the Responsible Person?

Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person is typically:

• The employer (where the workplace is under their control)
• The building owner or landlord
• The person in control of the premises

In practice, facilities managers are often treated as the Responsible Person where they:

• Oversee building maintenance and safety systems
• Instruct fire alarm and emergency lighting contractors
• Control escape routes and housekeeping
• Manage fire safety signage and procedures
• Employ staff working within the premises
• Control contractor access and hot works

Even where the organisation (rather than the individual) is the formal Responsible Person, enforcement authorities will examine who exercised practical control in the event of a breach.

Delegation does not remove accountability.

What Does the Fire Safety Order Require?

Under Articles 8 and 9 of the Fire Safety Order, the Responsible Person must:

• Take general fire precautions
• Carry out a suitable and sufficient fire risk assessment
• Implement appropriate fire safety measures
• Maintain fire safety systems
• Record significant findings (where required)
• Review the assessment where necessary

In addition, Article 11 requires the Responsible Person to establish appropriate fire safety arrangements, including planning, organisation, control, monitoring and review of preventive and protective measures.

Article 18 also requires the appointment of one or more competent persons to assist in undertaking preventive and protective measures.

“Relevant persons” include employees, visitors, contractors and anyone lawfully on the premises.

Breach of the Fire Safety Order is a criminal offence. Enforcement action is taken by the local Fire and Rescue Authority.

What Should a Fire Risk Assessment Cover?

For commercial premises managed by facilities teams, the assessment typically considers:

• Means of escape and travel distances
• Fire alarm category and coverage
• Emergency lighting provision
• Fire door condition and compartmentation
• Firefighting equipment
• Storage and housekeeping standards
• Electrical systems and ignition sources
• Contractor controls and hot works
• Staff training and evacuation procedures

The assessment must be building-specific. Generic templates or copy-and-paste reports are a common enforcement issue.

Routine Fire Safety Management Duties

In addition to maintaining a suitable and sufficient fire risk assessment, facilities managers must ensure ongoing compliance activities are completed and recorded. These commonly include:

• Weekly fire alarm testing (where required)
• Monthly and annual emergency lighting testing
• Routine fire door inspections
• Periodic servicing of firefighting equipment
• Staff fire safety training and evacuation drills
• Control of hot works and contractor permits

Failure to evidence routine compliance is a common enforcement issue.

Multi-Tenant Commercial Buildings

In multi-let offices or mixed-use premises, responsibility may be shared:

• Tenants are usually responsible for their demised areas
• The landlord or managing agent controls common parts
• The facilities manager may coordinate the overall fire strategy

The Fire Safety Order requires duty holders to cooperate and coordinate. This includes:

• Alarm testing and maintenance schedules
• Shared escape routes
• Final exits and assembly points
• Fire stopping and contractor works

Poor coordination between tenants and landlords is a common enforcement failing.

Facilities Managers in Residential or Mixed-Use Buildings

Where facilities managers oversee buildings containing flats, additional legislation may apply.

The Fire Safety Act 2021 clarified that the Fire Safety Order applies to building structure, external walls and flat entrance doors in residential buildings.

In England, the Fire Safety (England) Regulations 2022 introduced additional duties relating to resident information and fire door checks in multi-occupied residential buildings.

Facilities managers working within residential or mixed-use environments must ensure that fire risk assessments reflect this expanded scope and that compliance processes align with these additional requirements.

How Often Must a Fire Risk Assessment Be Reviewed?

There is no fixed statutory interval. However, the fire risk assessment must be kept under review and revised where necessary.

Review is required following:

• Material alterations or refurbishment
• Changes in occupancy or staffing levels
• Changes to fire safety systems
• A fire or significant near miss
• Identification of recurring defects

Review frequency should be risk-based. Higher-risk environments (e.g. sleeping risk, vulnerable occupants, complex layouts) require more frequent review than low-risk offices.

Many facilities managers adopt an annual review cycle as a practical baseline, with more frequent re-inspection for higher-risk buildings.

What Happens If a Facilities Manager Fails to Comply?

If you are treated as the Responsible Person (or acting as the person in control), enforcement action can include:

• Alterations Notices
• Enforcement Notices
• Prohibition Notices
• Criminal prosecution
• Unlimited fines
• Imprisonment in serious cases

Where an offence is committed by a company, directors or senior managers may also face personal liability if offences occur with consent, connivance or neglect.

In addition to criminal risk, facilities managers may face:

• Professional disciplinary consequences
• Contractual claims
• Reputational damage
• Insurer scrutiny after incidents

Fire Risk Assessment for Facilities Managers – Quick Compliance Summary

If you manage commercial premises, you must ensure:

• A current, suitable and sufficient fire risk assessment is in place
• Actions are prioritised and tracked to completion
• Fire alarm, emergency lighting and equipment maintenance is evidenced
• Escape routes are protected and unobstructed
• Contractors are properly controlled
• Staff receive appropriate fire safety training

Effective documentation and evidence are critical to demonstrating compliance if inspected.

Why Professional Assessment Matters

Facilities managers are often judged not simply on whether an FRA exists, but on whether fire safety is actively managed.

Common compliance failures include:

• Outdated or generic assessments
• Poor action tracking
• Inadequate fire door management
• Weak contractor oversight
• Inconsistent maintenance records

A competent fire risk assessment provides a defensible baseline and clear prioritised action plan.

For facilities managers overseeing multiple sites or complex premises, consistent reporting formats and prioritised action plans are essential. Clear documentation supports internal governance, insurer requirements and Fire and Rescue Authority inspections.

Conclusion

Facilities managers play a central role in delivering fire safety compliance across commercial and mixed-use buildings. While legal responsibility under the Fire Safety Order rests with the Responsible Person, facilities managers frequently exercise the practical control that enforcement authorities will examine.

Ensuring that a suitable and sufficient fire risk assessment is in place — and that its findings are implemented and evidenced — is essential to protecting occupants and reducing legal and professional risk.

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

If you require a compliant fire risk assessment, speak to our team today.

Frequently Asked Questions

Are Facilities Managers the Responsible Person Under the Fire Safety Order?

A facilities manager may be treated as the Responsible Person if they have control of the premises or control of fire safety arrangements in practice. Under the Regulatory Reform (Fire Safety) Order 2005, responsibility depends on control rather than job title. Where a facilities manager oversees maintenance, safety systems and evacuation procedures, they may carry legal duties.

Do Facilities Managers Have to Arrange a Fire Risk Assessment?

In most commercial buildings, yes. If you manage the premises or control fire safety systems, you must ensure a suitable and sufficient fire risk assessment is in place and kept under review. Even where the employer or landlord is formally the Responsible Person, facilities managers are typically responsible for arranging assessments and implementing actions.

What Happens If a Fire Risk Assessment Is Out of Date?

If a fire risk assessment is not reviewed when circumstances change, the organisation may be in breach of the Fire Safety Order. Enforcement action can include Enforcement Notices, Prohibition Notices, prosecution and unlimited fines. Facilities managers should ensure assessments are reviewed after alterations, occupancy changes, system changes or fire incidents.

How Often Should a Facilities Manager Review a Fire Risk Assessment?

There is no fixed statutory review period. The assessment must be reviewed where necessary and kept up to date. In practice, review frequency should be risk-based. Higher-risk premises such as sleeping accommodation or complex buildings require more frequent review than low-risk office environments. Many organisations adopt an annual review cycle as a baseline.

Can a Facilities Manager Be Personally Prosecuted?

Yes, in certain circumstances. Where an offence under the Fire Safety Order is committed by a company and is proven to have occurred with the consent, connivance or neglect of a manager or senior officer, that individual may be prosecuted. This is why documented oversight and action tracking are essential.

Does the Fire Safety Order Apply to All Commercial Buildings?

The Fire Safety Order applies to almost all non-domestic premises in England and Wales. This includes offices, retail units, warehouses, hotels, care homes and shared areas of multi-occupied residential buildings. If people work in or visit the premises, fire safety legislation is likely to apply.

What Evidence Should a Facilities Manager Keep for Fire Safety Compliance?

Facilities managers should retain current fire risk assessments, action plans with completion records, fire alarm and emergency lighting maintenance certificates, fire door inspection records, evacuation procedure documentation and staff training records. Clear documentation is critical to demonstrating compliance during inspection or following an incident.