How Fire Risk Assessments Link to FRAEW

Fire Risk Appraisal of External Walls (FRAEW) and traditional fire risk assessments (FRA) are related but distinct components of fire safety management in the UK. Following the Fire Safety Act 2021 and the introduction of PAS 9980:2022, the assessment of external wall systems has become a clearer and more defined regulatory responsibility for Responsible Persons.

In this guide, we explain how FRAEW and fire risk assessments interrelate, where their scopes overlap, and how duty holders should integrate both into a coherent and legally compliant fire safety strategy.

What a Fire Risk Assessment Covers

A fire risk assessment is a legally required evaluation of fire hazards, who is at risk, control measures in place, and actions required to manage those risks. Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must ensure a suitable and sufficient fire risk assessment is carried out for most non-domestic premises and the common parts of residential buildings.

A typical fire risk assessment considers:

• Identification of fire hazards
• Identification of people at risk
• Evaluation of fire safety measures
• Prioritised actions to reduce risk
• Recording of significant findings and required actions

However, traditional fire risk assessments do not necessarily include detailed technical analysis of external wall systems, such as assessing combustibility or façade construction behaviour under fire conditions.

What FRAEW (Fire Risk Appraisal of External Walls) Involves

Fire Risk Appraisal of External Walls (FRAEW) developed in response to increased scrutiny of external wall systems following high-profile fires involving combustible cladding. It is a focused technical appraisal of a building’s external wall construction to determine whether it presents a risk to life safety and whether remedial or interim measures are required.

FRAEW examines how the façade system performs in fire conditions and whether its design, materials or installation could contribute to rapid fire spread.

A typical FRAEW may include:

• Detailed examination of cladding materials
• Inspection of insulation and substrate materials
• Assessment of cavity barriers and compartmentation
• Evaluation of fire stopping at openings and penetrations
• Review of relevant test evidence (e.g., BS 8414 / BRE test data)

A typical FRAEW may include:

• Detailed review of cladding materials and their combustibility
• Inspection of insulation, sheathing and substrate components
• Assessment of cavity barriers and external compartmentation
• Evaluation of fire stopping at openings, penetrations and interfaces
• Review of available test data and certification (for example, BS 8414 large-scale façade testing)

External wall systems are assessed against the principles set out in Approved Document B of the Building Regulations, alongside relevant British Standards and fire performance guidance. Where applicable, large-scale testing such as BS 8414 may be referenced to evaluate system behaviour under fire exposure.

Unlike a general fire risk assessment, which primarily focuses on internal hazards, escape routes and management arrangements, FRAEW concentrates specifically on the fire performance of the building envelope — particularly where combustible materials or complex façade assemblies are present.

The Role of PAS 9980 in FRAEW

In the UK, FRAEW is commonly carried out in accordance with PAS 9980:2022, which provides a structured methodology for undertaking a fire risk appraisal of external wall construction in existing blocks of flats.

PAS 9980 promotes a risk-based, life safety–focused approach rather than a purely prescriptive or test-based assessment. It considers factors such as building height, use, means of escape, materials present, and fire spread potential.

Where applicable, FRAEW reports reference PAS 9980 to demonstrate that the appraisal follows recognised UK best practice.

Why Fire Risk Assessments and FRAEW Are Linked

The two assessments are linked through legal duty, risk management logic and overlapping risk domains.

1. Legal Responsibility (Responsible Person Duty)

Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must ensure a suitable and sufficient fire risk assessment is carried out. While the legislation doesn’t explicitly mandate FRAEW, it does expect the risk assessment to consider all hazards that could cause harm in the event of fire, including those originating outside the building envelope.

If external wall defects or combustible cladding present a realistic fire risk or impact means of escape, this should be captured in the risk assessment findings.

2. Risk Identification and Linkage

A competent fire risk assessor will identify external wall risk where it affects life safety and means of escape. For example:

• Combustible external wall materials may increase fire spread potential
• Poorly designed cavity barriers can undermine compartmentation
• Defects in insulation or cladding may create additional ignition paths

These should be recorded as significant findings in the fire risk assessment, with actions to manage or mitigate the external wall risk.

3. Prioritising Actions

FRAEW can inform the prioritisation of actions identified in a fire risk assessment. For example:

• If FRAEW identifies highly combustible cladding on a façade, the fire risk assessment might prioritise interim safety measures (e.g., enhanced detection, compartmentation upgrades, waking watch) while remediation solutions are planned.
• Where external wall risk intersects with internal escape routes, these risks must be reflected in both assessments.

4. Supporting Fire Strategy Documentation

In larger or more complex buildings, fire risk assessment and FRAEW will often both feed into a broader fire safety strategy document. A fire strategy may summarise internal hazards (from FRA), external wall performance (from FRAEW), engineered controls, evacuation strategy, and planned remediation solutions.

How Assessors Should Integrate FRAEW Into Fire Risk Assessment Reporting

Given the different focus areas, a robust approach involves:

A. Cross-Referencing Findings

Fire risk assessors should:

• Record significant external wall concerns identified through FRAEW
• Link them to internal life safety risks where relevant
• Propose coherent actions that align with both internal and external risk context

B. Collaborative Expertise

Sometimes a FRAEW requires specialist knowledge beyond general fire risk assessment competence. In such cases:

• A specialist (e.g., fire engineer or external wall expert) may conduct the FRAEW
• The fire risk assessor incorporates those findings into the fire risk assessment report

This collaborative approach ensures that risk evaluations address both internal and external fire dynamics.

Practical Examples of Linkage

Example 1 — Combustible Cladding

FRAEW Finding: Combustible insulation identified on outer façade
FRA Integration: Record this as a significant finding; consider effect on evacuation safety and interior fire dynamics; recommend interim measures

Example 2 — Poor Cavity Barriers

FRAEW Finding: Cavity barriers in the external wall are missing or non-compliant
FRA Integration: Document risk of fire spread across compartments; recommend remediation to support internal compartmentation

Example 3 — Fire Engineer Input

FRAEW Finding: Complex façade system requires performance-based analysis
FRA Integration: Summarise technical findings and integrate actionable controls into the fire risk assessment.

Compliance and Enforcement Considerations

Fire and Rescue Authorities increasingly expect visible due diligence where external wall issues are present. A fire risk assessment without any consideration of external wall issues in relevant buildings may be judged less comprehensive during an enforcement audit.

Where external wall risk is identified, the fire risk assessment report should clearly explain:

• What was found (external wall risk)
• How it affects life safety or compliance
• What actions are required and by when

This helps demonstrate that the Responsible Person has taken reasonable steps to address combined internal and external hazards.

The Fire Safety Act 2021 clarified that the Fire Safety Order applies to the structure and external walls of buildings, including cladding, balconies and windows. This legislative clarification reinforces the need to consider external wall fire risk where relevant.

How the Fire Safety Act 2021 Changed External Wall Risk Considerations

The Fire Safety Act 2021 clarified that external walls form part of the scope of fire safety legislation. This includes cladding systems, balconies, insulation and attachments to the exterior of a building.

As a result, Responsible Persons must ensure that external wall risks are considered where they may affect life safety. In practice, this has increased the importance of FRAEW in buildings with complex façade systems or combustible materials.

When Is FRAEW Required?

FRAEW is typically required where:

• The building is a block of flats or residential building with external wall systems
• Combustible cladding or insulation is present or suspected
• There are concerns about façade fire spread
• Lenders or insurers require clarification
• The fire risk assessment identifies potential external wall concerns

Not every building requires a formal FRAEW. However, where external wall construction may affect life safety, a competent appraisal is essential.

Conclusion

Fire Risk Assessment and Fire Risk Appraisal of External Walls (FRAEW) are distinct components of fire safety evaluation, but they are closely linked in practice.

A thorough fire risk assessment should:

• Identify internal fire hazards and risks
• Factor in external wall risk where it affects internal safety outcomes
• Record significant external wall findings if relevant
• Prioritise actions informed by both internal and external risk appraisal

By integrating FRAEW findings into the fire risk assessment process, duty holders can demonstrate a more complete risk management approach that aligns with UK fire safety expectations.

At Fire Risk Assessment Network, we help clients understand how FRA and FRAEW interlink and support duty holders in both internal and external wall risk appraisal. If you need support with either or both, contact us today for a free quotation.

Frequently Asked Questions

What is the difference between a fire risk assessment and FRAEW?

A fire risk assessment evaluates internal fire hazards, people at risk, and existing control measures within a building. FRAEW (Fire Risk Appraisal of External Walls) specifically assesses the fire performance and combustibility of external wall systems, including cladding, insulation and cavity barriers. FRAEW is more technical and focused on façade construction, while the fire risk assessment considers overall life safety management.

Does UK law require a FRAEW?

UK legislation requires a suitable and sufficient fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005. It does not explicitly mandate FRAEW by name. However, where external wall systems present a potential fire risk, a competent assessment should address that risk — and in many cases this involves a formal FRAEW.

When should a building have both a fire risk assessment and a FRAEW?

Both may be required where a building contains cladding systems, complex external wall assemblies, combustible insulation, or where there are concerns about fire spread across façades. FRAEW provides detailed technical analysis, while the fire risk assessment integrates those findings into life safety management and action planning.

Who is responsible for commissioning FRAEW?

The Responsible Person under fire safety legislation holds the legal duty to ensure fire risks are properly assessed. In residential buildings, this is often the building owner, freeholder or managing agent. They may appoint specialist consultants to carry out FRAEW where required.

How do FRAEW findings affect a fire risk assessment?

If FRAEW identifies combustible materials, missing cavity barriers or other façade risks, these should be recorded as significant findings within the fire risk assessment. The assessor may recommend interim measures, remediation works or revised evacuation strategies depending on the level of risk identified.

Is FRAEW the same as an EWS1 assessment?

No. An EWS1 form is primarily a valuation and lending tool used by mortgage lenders to assess external wall systems for marketability purposes. FRAEW is a fire safety appraisal focused on life safety and regulatory compliance. While both relate to external walls, they serve different functions.

Can a fire risk assessor carry out FRAEW?

Some fire risk assessors may have the competence and technical expertise to assess external wall systems. However, FRAEW often requires specialist knowledge of façade construction, materials testing and fire engineering principles. In complex cases, collaboration with a fire engineer or façade specialist may be appropriate.

What happens if external wall risks are identified?

If significant external wall risks are found, the Responsible Person should implement proportionate control measures. This may include interim risk management (such as enhanced detection or revised evacuation procedures) and longer-term remediation planning. Clear documentation and prioritisation of actions are essential to demonstrate compliance.