Quick Answer: When Is a FRAEW Required?<\/h2>\n
A FRAEW is required where external wall systems in a multi-occupied residential building may present a life safety risk. This typically includes buildings with cladding, combustible insulation, or fa\u00e7ade systems that could contribute to fire spread. The requirement is risk-based under PAS 9980 and UK fire safety legislation, not determined by height alone.<\/p>\n
What Does \u201cRequired\u201d Really Mean?<\/h2>\n
A FRAEW<\/a> is not an automatic statutory requirement for every building. Instead, it becomes necessary when risk indicators suggest that external wall construction may affect life safety.<\/p>\n This reflects the UK legal framework, where the Regulatory Reform (Fire Safety) Order 2005<\/a> places a duty on the Responsible Person to ensure fire risks \u2014 including those from external walls \u2014 are identified and mitigated so far as is reasonably practicable. The Fire Safety Act 2021<\/a> clarifies that external walls, cladding, balconies and attachments fall within the scope of that duty.<\/p>\n PAS 9980 requires a structured evaluation of both the likelihood of fire spread over the external wall and the potential consequences for occupants. A FRAEW becomes necessary where external wall risk cannot be reasonably discounted through available documentation review or non-intrusive inspection.<\/p>\n PAS 9980 requires assessors to consider both the probability of external fire spread and the consequences for occupants, including the effectiveness of evacuation strategy (such as stay-put or simultaneous evacuation), the reliability of compartmentation and the potential for rapid vertical fire spread via fa\u00e7ade systems.<\/p>\n PAS 9980 applies specifically to existing multi-occupied residential buildings in England.<\/p>\n In practical terms, a FRAEW is required where external wall construction could materially affect life safety, including evacuation strategy, compartmentation integrity, or rapid fire spread across fa\u00e7ades \u2014 not simply because a building exceeds a particular height threshold.<\/p>\n FRAEW is primarily relevant to existing multi-occupied residential buildings where external wall systems could affect life safety.<\/p>\n This typically includes:<\/p>\n FRAEW is not generally required for:<\/p>\n The requirement is driven by risk and occupancy type, not simply building height.<\/p>\n Here are the main situations where competent practitioners will typically recommend or require a FRAEW:<\/p>\n Buildings with cladding or composite wall systems \u2014 particularly those with combustible components \u2014 have an elevated potential for fire spread. Where such systems are present, a FRAEW helps determine whether that risk is significant and what actions are required.<\/p>\n Certain types of insulation materials are more likely to contribute to rapid fire spread. If insulation in the external wall is not clearly non-combustible or fire-tested, this is a trigger for FRAEW \u2014 even if the cladding itself is compliant.<\/p>\n A competent fire risk assessment may flag<\/a> external wall systems as a potential risk influencing life safety. In these cases, a FRAEW is the logical next step to investigate fa\u00e7ade performance more deeply.<\/p>\n Fire risk assessors should refer to PAS 9980<\/a> when deciding whether external wall risk requires formal appraisal.<\/p>\n External wall systems are typically considered with reference to Approved Document B<\/a>, which sets out fire performance expectations under the Building Regulations in England.<\/p>\n Fire and Rescue Authorities or Building Control may require a FRAEW where external wall risk is identified during inspection, audit or enforcement activity. This is particularly common where external wall concerns intersect with means of escape or compartmentation.<\/p>\n Following the Fire Safety Act 2021, responsibility for external walls is clearly within fire safety legislation\u2019s scope. Professional guidance (including PAS 9980) now explicitly considers external wall fire risk as part of a suitable and sufficient risk assessment where relevant.<\/p>\n Many stakeholders assume that external wall appraisal is automatically required above a certain building height (for example, 11m or 18m). In practice:<\/p>\n That said, buildings over 18 metres with cladding or complex fa\u00e7ades are much more likely to require a FRAEW because the potential consequences of fire spread are higher.<\/p>\n For example, a 12-metre residential building with combustible insulation and poorly detailed cavity barriers may require a FRAEW, while a 20-metre building constructed entirely with non-combustible materials and robust compartmentation may not.<\/p>\n The decision depends on fa\u00e7ade construction, materials, and life safety impact \u2014 not height alone.<\/p>\n If a building undergoes a significant change of use, occupancy or structural modification \u2014 particularly affecting external walls \u2014 a new appraisal should be considered.<\/p>\n While distinct from EWS1 forms (which support lending\/valuation), a FRAEW may be recommended during due diligence if fa\u00e7ade fire risk is present \u2014 particularly where lenders or purchasers express concern.<\/p>\n EWS1 is governed by lender and valuation protocols, as outlined in RICS EWS1 guidance<\/a>, and serves a different purpose to FRAEW.<\/a><\/p>\n External walls can change over time due to:<\/p>\n If any of these occur, a FRAEW can help reassess risk.<\/p>\n The decision should be made by a competent professional with:<\/p>\n This may include fire engineers, fa\u00e7ade consultants or specialist fire risk assessors with external wall expertise.<\/p>\n Importantly, the Responsible Person remains legally accountable for ensuring the correct appraisal is carried out where required.<\/p>\n A competent FRAEW report should clearly explain:<\/p>\n Clear documentation helps demonstrate that the Responsible Person has taken reasonable steps to assess and manage fire risk, which is critical in enforcement or audit situations.<\/p>\n At Fire Risk Assessment Network, we provide PAS 9980-aligned FRAEW services across the UK. Our specialists help duty holders understand when an appraisal is required, how risk is assessed and what actions can reduce life safety risk. Contact us today for expert guidance and a free quotation.<\/p>\n Our FRAEW appraisals are aligned with PAS 9980 and current UK fire safety legislation.<\/p>\n A FRAEW is required when external wall systems pose a potential life safety risk \u2014 not simply because of building height or typology.<\/p>\n Key triggers include:<\/p>\n Because FRAEW is risk-based and tied to life safety outcomes, the decision to commission one should always be evidence-led and aligned with current UK fire safety legislation and PAS 9980 methodology.<\/p>\nWhat Types of Buildings Does FRAEW Apply To?<\/h2>\n
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Key Factors That Trigger a FRAEW<\/h2>\n
1. Presence of Cladding or Composite Facades<\/h3>\n
2. Buildings with Combustible Insulation<\/h3>\n
3. Fire Risk Assessment Identifies External Wall Concerns<\/h3>\n
4. Enforcement or Regulatory Direction<\/h3>\n
5. Post-Legislative Clarification and Industry Guidance<\/h3>\n
Common Misconception: Height Alone Doesn\u2019t Trigger FRAEW<\/h2>\n
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Practical Example<\/h3>\n
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<\/p>\nOther Situations Where FRAEW May Be Recommended<\/h2>\n
Change of Use or Major Alteration<\/h3>\n
Sale or Transfer of a Residential Building<\/h3>\n
Periodic Re-evaluation of Fa\u00e7ade Performance<\/h3>\n
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Who Decides Whether a FRAEW Is Required?<\/h2>\n
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How a FRAEW Requirement Is Evidenced<\/h2>\n
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Professional FRAEW Support<\/h2>\n
Conclusion<\/h2>\n
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