BS 9792 vs PAS 79: Fire Risk Assessment Changes in 2025
BS 9792 vs PAS 79 guide to change to Fire Risk Assessments in 2025. If you act as the responsible person for a residential building, you need a fire risk assessment that stands up to scrutiny, supports real risk reduction, and gives you a clear action plan you can deliver through your contractors and managing systems.
In 2025, the biggest change for housing providers and block managers came through the move from PAS 79-2 to BS 9792:2025 for housing fire risk assessment. PAS 79-1 still matters, but it covers premises other than housing.
This article explains what changed, what stays the same, and what you should do differently when you procure, manage, and quality-check fire risk assessments across your portfolio.
It focuses on practical outcomes for block managers, housing associations, local authority housing teams, freeholders, and any organisation that controls common parts.
Scope of BS 9792 vs PAS 79, in plain terms
PAS 79 is a long-established set of guidance documents used to structure fire risk assessments. It helped standardise how assessors approach premises, record findings, and present recommendations.
The split you must understand is this:
- PAS 79-1 continues to cover fire risk assessments for non-housing premises.
- PAS 79-2 used to cover housing, but it has been withdrawn and replaced by BS 9792:2025, which now provides the housing-specific British Standard.
If you manage a mixed-use building, you often need both approaches. Your commercial areas and your residential areas create different risk profiles, different management responsibilities, and different assessment assumptions. You should not accept a single generic report that blurs those differences without clear scoping.
Why the change matters to you as the responsible person
You carry the legal duty to ensure you have a suitable and sufficient fire risk assessment and to implement appropriate fire precautions. If an incident, complaint, or enforcement action arises, you will need to show:
- How you assessed risk
- What evidence you relied on
- What you did about identified shortcomings
- How you managed limitations in access and information
- How you prioritised actions and tracked completion
BS 9792 pushes the process in that direction. In practice, it helps you separate three things that too many organisations still mix up:
- The fire risk assessment that identifies and evaluates risk
- The specialist surveys that generate evidence about compartmentation, fire doors, smoke control, or external walls
- The management system that closes actions and proves completion
BS 9792 vs PAS 79: the changes you will see in real work
1. Housing now has a dedicated British Standard with clearer assumptions
Housing blocks behave differently from many other premises. They rely heavily on fire-resisting construction and compartmentation, and they often operate stay put or phased evacuation strategies that depend on that integrity. They also contain residents with a wide range of capabilities and support needs.
BS 9792 focuses on housing realities. It deals with common parts, dwellings, and the management arrangements you control as the responsible person. That focus improves consistency and reduces the risk that the assessor applies workplace assumptions to residential buildings.
What you should do :
- When you instruct a housing FRA, require the assessor to confirm they will assess to BS 9792 and to state the building category and any specialist housing factors at the start of the report.
2. Stronger definition of assessment types, and a clearer link to intrusive inspection
A practical frustration for responsible persons has always been this: you receive a “Type 1” style FRA, the assessor raises compartmentation doubts, and your action plan fills up with “further investigation required” without a structured route to evidence.
BS 9792 clarifies four FRA types and ties them directly to what was inspected and whether the assessment included intrusive checks:
Type 1: Common parts only, non-intrusive
Type 2: Common parts, intrusive
Type 3: Common parts and dwellings, non-intrusive
Type 4: Common parts and dwellings, intrusive
The key impact for you is the evidence threshold. If you cannot evidence the integrity of compartmentation and key fire safety features, a non-intrusive approach may not give you a reliable risk picture. BS 9792 encourages the assessor to be explicit about this and to record where access or inspection constraints affect conclusions.
What you should do :
- Stop defaulting to “Type 1 every year” without evidence. Move to an evidence-led model:
- Use Type 1 where you already hold reliable evidence of compartmentation and fire safety features, such as recent compartmentation surveys, fire door surveys, as-built information, and a strong repair history.
- Commission Type 2 or targeted intrusive inspection where you lack evidence, where you manage higher risk buildings, or where you face repeated defects and unknowns.
- Use a planned programme for intrusive sampling across your portfolio, rather than reacting building by building after each FRA raises uncertainty.
3. Better discipline around limitations, sampling, and scope boundaries
Responsible persons often inherit weak reports that read well but hide key limitations. If the assessor could not access risers, ceiling voids, roof voids, plant rooms, or representative flat doors, you need that written clearly. You also need the report to explain what that limitation means for risk.
BS 9792 reinforces the need to record :
- What the assessor inspected
- What they could not inspect and why
- The effect of those limitations on conclusions
- Where the assessor requires specialist input beyond their competence
This matters because you manage risk by decision-making. If you do not know what the assessor did not see, you cannot judge whether your action plan addresses the true risk.
What you should do :
- Add acceptance criteria to your contract:
- The report must include an access and limitations section that lists all non-accessed areas and the reason.
- The report must define sampling for fire doors and compartmentation observations, and must record sample sizes and locations.
- The report must separate “known defects” from “unknowns due to limitations” and must recommend a clear next step for each unknown.
4. More explicit coverage of residents who need assistance to evacuate
Housing risk management sits at the intersection of building safety and people. Concerns around evacuation needs have driven stronger expectations for resident-focused planning in multi-occupied residential buildings.
BS 9792 includes clearer prompts around people with specific requirements. It also supports person-centred assessment approaches and encourages recording of arrangements that assist residents in preventing fire, responding to fire, or evacuating where necessary.
What you should do :
- Build a simple governance model:
- For general needs housing blocks operating stay put, ensure your building-based FRA clearly states the evacuation strategy and the assumptions that support it, especially compartmentation.
- For supported housing, extra care, or blocks with known resident vulnerabilities, plan person-centred assessments where appropriate and agree how you will manage information, consent, and updates.
- Align this work with your housing management and support teams. Fire safety cannot sit only with the compliance team in these settings.
5. Better fit with practical duties in England for high-rise and multi-occupied buildings
The Fire Safety (England) Regulations 2022 added practical requirements in England, including duties around information provision, wayfinding signage in certain buildings, secure information boxes in higher buildings, and routine checks of fire doors in relevant settings.
BS 9792’s housing-specific approach makes it easier for an assessor to capture these practical compliance points in a structured way. This supports you as the responsible person because you can connect the FRA action plan to your operational routines, inspection schedules, and contractor tasks.
What you should do :
- Make the FRA a compliance hub document:
- Use it to confirm what you do monthly, quarterly, and annually.
- Attach evidence references. For example, maintenance certificates, inspection logs, and defect closure records.
- Make sure the action plan does not just state “check” or “inspect”. It should assign responsibility, define frequency, and point to the record you will keep.
6. Fire doors and compartmentation: treat them as programmes, not isolated actions
Responsible persons in residential blocks face two consistent drivers of risk and enforcement attention:
- Flat entrance doors and communal fire doors
- Compartmentation failures, service penetrations, and hidden void risks
BS 9792 supports better treatment of these issues by requiring assessors to record and sample, and to describe shortcomings in construction and doors. But you still need to manage delivery through planned programmes because:
- A fire risk assessment rarely includes the breadth of intrusive inspection needed to prove compartmentation.
- Door performance and maintenance requires ongoing inspection and repair cycles.
What you should do :
Run two connected programmes:
Fire door programme
- Maintain a door asset register for communal doors and, where possible, flat entrance doors.
- Plan routine inspections in line with your building type and legal duties.
- Track defects to completion with photos, dates, and contractor sign-off.
Compartmentation programme
- Use a risk-based approach. Prioritise higher buildings, complex blocks, older stock, and blocks with repeated contractor works.
- Commission targeted intrusive inspections that focus on risers, service penetrations, ceiling voids, and roof voids where relevant.
- Require photographic evidence, annotated locations, and a clear remedial specification.
Then use your FRA as the place where you summarise the evidence you hold and identify where evidence gaps remain.
7. Digital reporting and photographic evidence: make it your standard
The practical reality is that digital evidence control is now essential for responsible persons managing residential portfolios, because it supports:
- Faster triage and prioritisation of actions
- Clear instructions to contractors
- Audit trail for internal governance and external scrutiny
- Consistency across multiple assessors and contractors
BS 9792 supports this approach through more structured recording prompts and clearer expectations around what was inspected and what was not.
What you should do :
- Specify it in procurement:
- Require digital reports with structured fields, not just narrative text.
- Require photo evidence for material defects and for key systems and facilities where it helps verification.
- Require annotated photos for compartmentation defects and door defects, with clear location references.
- Require a structured action plan with priorities and target timescales that you can import into your compliance system.
8. Modern ignition hazards and rapid fire development: lithium-ion risks
Residential buildings now face common hazards that older risk frameworks often understated. Lithium-ion batteries in e-bikes, e-scooters, mobility scooters, and power tools can create rapid fire development, toxic smoke, and explosive events. That can compromise escape routes quickly.
BS 9792 vs PAS 79 recognises these hazards directly in a housing context and expects the assessor to consider their presence and control measures.
What you should do :
- Control the risk through policy and design:
- Define clear rules for storage and charging in common parts. Enforce them.
- Provide suitable storage solutions where feasible.
- Work with resident engagement teams to explain the rule, the reason, and the consequences.
- Review refuse and storage rooms, corridors, and lobbies for signs of charging and storage. Treat it as a routine management inspection item.
Competence and third-party certification: what you should demand as the responsible person
Your risk profile depends heavily on assessor competence. Housing FRAs require understanding of:
- Evacuation strategies common in flats, including stay put assumptions and when they fail
- Construction and compartmentation indicators, including typical failure points in older and modified buildings
- Fire doors in a housing context, including practical defects, resident behaviours, and maintenance arrangements
- How to express limitations and evidence needs clearly, without hiding uncertainty
- The interface between life safety FRA and specialist assessments such as external wall appraisal
Third-party certification can help you procure consistently, but you still need to set building-specific requirements. If you ask for BAFE certification, make sure you specify the right scope.
For example, BAFE SP205 applies to life safety fire risk assessment. It does not cover external wall appraisals or destructive cladding inspections. You should procure FRAEW, PAS 9980 style appraisals, or other external wall work separately where needed.
What you should do :
- Build a simple competence matrix into your tender:
- Minimum competence: relevant qualifications, membership, CPD, and demonstrable housing stock experience
- Portfolio match: experience with your building heights, construction types, and occupancy profiles
- Evidence approach: ability to deliver digital reporting, photos, and structured action plans
- Escalation capability: ability to identify when specialist input is required and to define the scope of that input clearly
- Quality assurance: peer review for higher risk buildings or high consequence premises
How to implement BS 9792 across a housing portfolio
Responsible persons often struggle not with one building, but with consistency across hundreds of buildings. You can make BS 9792 work for you by creating a portfolio-level framework.
Step 1: Classify your buildings
Create a simple classification:
- Building height and firefighting access complexity
- Construction era and known compartmentation risk indicators
- Presence of smoke control systems or complex firefighting facilities
- Resident profile, including supported housing or higher vulnerability
- History of fire door defects and contractor works
Step 2: Decide the assessment type strategy
Do not decide type building by building in isolation. Set a policy:
- Type 1 for lower complexity buildings with good evidence
- Type 2 for higher complexity buildings and evidence gaps
- Targeted intrusive inspection programme for compartmentation and risers where evidence gaps persist
- Separate dwelling access programme where needed for Type 3 or Type 4 style assessments
Step 3: Standardise your reporting outputs
Set a standard format across all assessors:
- Common risk rating approach
- Standard action plan categories
- Photo evidence rules
- Mandatory sections for limitations, sampling, and evidence references
Step 4: Integrate action plans into your compliance system
If you manage actions on spreadsheets, move to a controlled tracker. If you already have a CAFM or compliance tool, build an import routine. Each action should have:
- Owner
- Priority
- Target date
- Evidence required to close
- Reinspection requirement
Step 5: Link FRA actions to planned programmes
Many of your FRA actions will feed directly into:
- Fire door inspections and repairs
- Compartmentation surveys and fire stopping programmes
- Smoke control servicing and specialist investigations
- Resident communication and engagement
If you treat these as programmes, you deliver faster risk reduction and you reduce repeat actions across annual FRAs.
Common mistakes responsible persons make when transitioning to BS 9792 vs PAS 79
Mistake 1: Keeping old templates and old language
If your brief still references PAS 79-2 or uses outdated type descriptions, you create procurement confusion and you raise the risk of inconsistent outputs.
Solution:
Update your brief templates. Require BS 9792 for housing and require clear statement of FRA type under BS 9792 definitions.
Mistake 2: Accepting vague conclusions without evidence
A housing FRA that asserts compartmentation integrity without evidence gives you false confidence.
Solution:
Require evidence references. If the assessor cannot evidence integrity, require a defined next step, such as Type 2 sampling or a compartmentation survey.
Mistake 3: Expecting the FRA to substitute for specialist surveys
A good FRA identifies problems and risk. It rarely proves construction performance at scale without intrusive work.
Solution:
Procure specialist surveys as programmes and use the FRA to set priorities and confirm risk reduction.
Mistake 4: Not enforcing limitations reporting
If you let limitations slide, you lose your audit trail and you risk making poor prioritisation decisions.
Solution:
Reject reports that do not clearly list non-inspected areas, sampling basis, and effect on risk conclusions.
FAQs : BS 9792 vs PAS 79
1. What is the key difference in BS 9792 vs PAS 79 for housing?
BS 9792:2025 now provides the housing-specific British Standard and replaces PAS 79-2 for housing. PAS 79-1 still covers non-housing premises.
2. Do you still use PAS 79 at all if you manage residential blocks?
Yes, in mixed-use settings you still use PAS 79-1 for the non-housing elements. For the housing parts, you should use BS 9792.
3. What are the four FRA types in BS 9792 and why do they matter to you?
They define what areas the assessor covered and whether the work was intrusive. That affects how much you can rely on conclusions about compartmentation, service risers, voids, and other hidden risks.
4. When should you move from a Type 1 style assessment to intrusive work?
Move to intrusive work when you lack reliable evidence of compartmentation and fire safety features, when the building complexity increases, when you have repeat defects, or when you manage higher consequence buildings. Use a planned programme rather than a reactive approach.
5. Does BS 9792 require photographic evidence?
BS 9792 supports stronger recording and clearer documentation. You should still specify photographic evidence in your contract because it gives you a better audit trail and faster defect closure.
6. Can you rely on a housing FRA to confirm compartmentation?
A housing FRA can identify indicators and likely weaknesses, but you often need intrusive inspection and compartmentation surveys to confirm integrity. Treat compartmentation as an evidence programme.
7. How should you handle fire doors alongside a BS 9792 assessment?
Use the FRA to set priorities and identify defects, then run a structured fire door inspection and maintenance programme with an asset register, routine checks, defect tracking, and evidence of completion.
8. Does BAFE certification cover everything you need as a responsible person?
BAFE SP205 covers life safety fire risk assessment. It does not cover external wall appraisals or destructive cladding inspections. Procure those separately where needed.
9. What should you insist on when you receive a BS 9792 housing FRA report?
Insist on clear scope, the BS 9792 FRA type, sampling and limitations, photo evidence for material defects, and a structured action plan you can track to completion.
10. How often should you review your approach after switching to BS 9792?
Review it after your first portfolio cycle under BS 9792. Track how many actions repeat due to evidence gaps, how often limitations prevent conclusions, and where planned programmes reduce repeat findings. Then adjust your inspection strategy and procurement requirements.
Conclusion : BS 9792 vs PAS 79
BS 9792 gives you a better housing-specific framework, but you still control the outcome through how you procure, how you enforce evidence standards, and how you deliver actions.
If you manage blocks or housing stock, your quickest compliance improvement comes from three moves:
- Specify BS 9792 for housing and standardise report outputs across your portfolio
- Use an evidence-led approach to intrusive inspection rather than defaulting to non-intrusive assessments
- Run fire door and compartmentation work as planned programmes with digital evidence and defect closure tracking
Need help with a Fire Risk Assessment?
Anstey Horne’s expert team of fire safety professionals are here to assist with legally compliant fire risk assessments, retrospective fire strategies, and FRAEW appraisals for residential buildings across the UK. Whether you manage a single block or a national portfolio, we can help you stay safe and compliant.
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