How To Close Out Fire Risk Assessment Actions Properly

Completing a fire risk assessment action is only part of compliance. Properly closing out that action — with appropriate evidence and documentation — is what demonstrates that the risk has genuinely been addressed.

Under the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must implement appropriate fire safety measures and maintain adequate arrangements. In enforcement investigations, Fire and Rescue Authorities commonly focus not on whether an action was marked “complete” — but whether there is sufficient evidence to support that closure.

This guide explains how to close out fire risk assessment (FRA) actions properly, what evidence is acceptable, and how to avoid common compliance failures.

If you require support reviewing or strengthening your fire safety documentation, contact us for a free, no-obligation quotation.

Why Proper Close-Out Matters

A frequent enforcement issue is the premature closure of actions without verification.

Common examples include:

• Fire door repairs marked complete with no inspection record
• Alarm servicing completed but certificates not retained
• Compartmentation works undertaken without evidence of fire stopping quality
• High-risk actions left open indefinitely

Closing an action properly requires:

• Confirmation that the deficiency has been rectified
• Evidence that the corrective measure is suitable
• Records that demonstrate compliance

Without documentation, enforcement authorities may treat the action as incomplete.

Where the original fire risk assessment recorded “significant findings”, those findings must be implemented and evidenced. Closing actions properly is therefore not administrative — it is part of demonstrating compliance with Articles 8 and 9 of the Fire Safety Order.

Step 1: Confirm the Original Deficiency

Before closing an action, ensure you clearly understand:

• What the original finding was
• The level of risk assigned
• The recommended remedial measure

An action should not be closed simply because “work has been done”. It should be closed because the original risk has been reduced to an acceptable level.

Step 2: Determine What Evidence Is Required

The level of evidence should be proportionate to risk.

High-Risk Actions

Examples:

• Compromised protected escape routes
• Missing or defective fire doors
• Inoperative fire alarm systems
• Significant compartmentation breaches

Acceptable evidence may include:

• Contractor completion certificates
• Commissioning certificates
• Third-party accreditation details
• Photographic evidence (before and after)
• Updated maintenance logs
• Written confirmation from a competent person

High-risk issues generally require formal, auditable evidence.

Medium-Risk Actions

Examples:

• Inadequate signage
• Minor door hardware defects
• Housekeeping improvements

Evidence may include:

• Photographs
• Maintenance records
• Signed internal inspection reports

Low-Risk Improvements

Examples:

• Advisory improvements
• Policy clarifications
• Minor documentation updates

Evidence may include:

• Updated policy documents
• Meeting minutes
• Internal sign-off

The key principle: Evidence should match the seriousness of the risk.

Step 3: Acceptable Types of Evidence

The following forms of evidence are commonly acceptable:

Photographic Evidence

Useful for:

• Fire door condition
• Signage installation
• Escape route clearance
• Minor remedial works

Best practice:

• Date-stamped images
• Before-and-after comparison
• Clear identification of location

Photographs alone may not be sufficient for complex or structural issues.

Contractor Certificates

Appropriate for:

• Fire alarm installation or modification
• Emergency lighting commissioning
• Fire stopping works
• Fire door installation
• Electrical works

Certificates should:

• Identify the building
• Describe the work completed
• Be signed by a competent contractor

Retain copies securely.

Inspection & Commissioning Records

These may include:

• Alarm commissioning sheets
• Emergency lighting test certificates
• Fire door inspection reports
• Compartmentation surveys

Inspection records provide defensible technical evidence.

Written Sign-Off

For some actions, internal confirmation may be sufficient.

For example:

• Policy updates
• Staff training completion
• Procedure changes

However, internal sign-off should:

• Be dated
• Identify the responsible person
• Reference the original action

Step 4: Verify That the Risk Is Controlled

Closing an action should involve verification.

Ask:

• Has the hazard been eliminated?
• Has the risk been reduced to an acceptable level?
• Does the control measure align with current standards?
• Would this withstand inspection?

Premature closure is a common compliance weakness.

In some cases, particularly where structural fire protection or fire strategy elements are involved, the fire risk assessment itself may require partial review or amendment following completion of works. The assessment should reflect the updated condition of the building.

Step 5: Update the Action Plan Record

A properly closed action should include:

• Completion date
• Responsible person
• Summary of work undertaken
• Evidence reference (certificate number, file location)
• Status updated to “Closed”

Maintain an audit trail.

Evidence should not only be retained, but be readily retrievable. During inspection, delays in producing certificates or records can undermine confidence in compliance arrangements.

Interim Measures & Partial Closure

Where full rectification cannot be completed immediately:

• Implement interim control measures
• Document the temporary control
• Set revised completion deadline

An action should not be marked fully “closed” unless the permanent solution has been completed.

Common Close-Out Mistakes

• Marking actions complete without evidence
• Relying solely on verbal confirmation
• Losing certificates or inspection records
• Closing actions before follow-up inspection
• Failing to review related risks

These issues often surface during Fire Authority inspections or after incidents.

Enforcement Perspective

Under Article 32 of the Fire Safety Order, failure to comply with duties may result in prosecution.

Enforcement authorities frequently examine:

• Whether significant findings were implemented
• Whether completion evidence exists
• Whether delays were reasonable
• Whether high-risk issues were prioritised

Documented evidence is critical.

Digital vs Manual Close-Out Systems

Many organisations now use:

• Digital compliance dashboards
• Document management systems
• Automated action tracking
• Escalation alerts

Manual systems (such as spreadsheets) can be compliant — provided records are consistent, current and securely retained.

The format matters less than the evidence.

Fire Risk Assessment Close-Out – Quick Checklist

Before closing an action, confirm:

• The original deficiency has been rectified
• The risk level has been addressed proportionately
• Appropriate evidence is retained
• The action plan has been updated
• Any related risks have been reviewed
• Interim measures (if used) are documented

If these steps are followed, your close-out process is far more likely to withstand inspection.

The Inspection Test

A simple test when closing any action is to ask:

• If an enforcing officer inspected tomorrow, could you clearly demonstrate what was wrong, what was done, and when it was resolved?
• Could you produce the supporting evidence within minutes?
• Would the documentation show that the risk was prioritised appropriately?

If the answer to any of these questions is uncertain, your close-out process may need strengthening.

Conclusion

Closing out fire risk assessment actions properly is essential to demonstrating compliance under the Regulatory Reform (Fire Safety) Order 2005. Simply marking an action as “complete” is not sufficient.

Evidence must be proportionate, verifiable and retained. High-risk issues require formal documentation and, where appropriate, contractor certification or independent verification.

At Fire Risk Assessment Network, we support organisations across the UK not only in delivering compliant fire risk assessments, but in reviewing and strengthening action tracking and close-out processes to ensure they stand up to inspection.

If you are unsure whether your action close-out process would withstand inspection, we can review your existing documentation and identify gaps before they become enforcement issues.

Frequently Asked Questions

How Do I Prove a Fire Risk Assessment Action Has Been Completed?

To demonstrate that an action has been properly completed, you should retain clear and proportionate evidence. This may include contractor certificates, commissioning records, dated photographs, updated maintenance logs, or written sign-off confirming that the original deficiency has been rectified. The evidence should directly relate to the specific finding identified in the fire risk assessment.

Are Photographs Acceptable Evidence for Closing an FRA Action?

Photographs can be acceptable evidence, particularly for visible issues such as signage installation, escape route clearance or minor fire door repairs. Best practice is to retain date-stamped “before and after” images clearly identifying the location. However, photographs alone may not be sufficient for complex issues such as compartmentation repairs, fire alarm commissioning or structural fire protection works.

Do I Need Contractor Certificates to Close an Action?

Contractor certificates are typically required for higher-risk or technical works. Examples include fire alarm installation or modification, emergency lighting commissioning, fire stopping, electrical works and fire door installation. Certificates should clearly identify the premises, describe the work undertaken and be signed by a competent contractor. These records provide defensible evidence during inspection.

Can I Close an Action Without Independent Verification?

For lower-risk or administrative actions, internal verification and sign-off may be sufficient. However, higher-risk issues should be verified by a competent person. Premature closure without appropriate verification is a common enforcement weakness and may result in action being treated as incomplete during inspection.

What Happens If FRA Actions Are Marked Complete Without Evidence?

If significant findings are marked complete but no supporting evidence is available, enforcement authorities may consider the action unimplemented. Under Article 32 of the Regulatory Reform (Fire Safety) Order 2005, failure to comply with duties may result in enforcement notices, prosecution or fines. Documentation is critical to demonstrating compliance.

Should Interim Measures Be Recorded?

Yes. Where permanent works cannot be completed immediately, interim control measures (such as additional monitoring, temporary detection or restricted access) should be documented. The action should not be fully closed until the permanent solution has been implemented.

How Long Should Evidence of Completed Actions Be Kept?

Fire safety documentation should be retained for as long as it remains relevant and in line with your organisation’s document retention policy. In practice, maintaining records until the next fire risk assessment review — and often longer — provides continuity and defensibility in the event of inspection or incident investigation.