Anstey Horne

Suitable and Sufficient Fire Risk Assessment Guide

suitable and sufficient fire risk assessment

A suitable and sufficient fire risk assessment is not a vague promise. It is the legal standard you must meet when you assess fire risks and decide what general fire precautions you need. In England and Wales, Article 9 of the Regulatory Reform (Fire Safety) Order 2005 requires the responsible person to make a suitable and sufficient assessment for the purpose of identifying the measures needed to comply.

This article explains what “suitable and sufficient fire risk assessment” means in practice, what enforcing authorities typically look for, and how you can build an assessment that stands up to scrutiny. It also gives you practical documentation tips, because evidence often decides whether your assessment looks credible.

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What “Suitable and Sufficient” Actually Means

Legislation does not define “suitable and sufficient” in a neat checklist. Guidance notes that the adequacy of an assessment involves judgement, and the right approach depends on the premises, the people, and the risk profile.

In practical terms, a suitable and sufficient fire risk assessment does three things well:

  1. It identifies who could be harmed and how. This includes occupants, visitors, contractors, and others who might lawfully be on the premises. It also includes people in the immediate vicinity who face risk from a fire in the premises, which UK guidance highlights when describing the purpose of the assessment.
  2. It identifies the right general fire precautions for the actual risk. The modern approach expects risk-proportionate controls. It moves away from blindly applying prescriptive rules without thinking, and toward controls that match the hazards, layout, occupants, and management capability.
  3. It records significant findings and produces an action plan you can deliver. UK guidance explains that significant findings should indicate measures taken and measures that will be taken to comply. It also highlights the duty to record significant findings and people especially at risk in certain circumstances.

If your assessment misses any of those, it will struggle to meet the suitable and sufficient standard.

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Why “Suitable and Sufficient” Often Fails in the Real World

Most weak assessments fail for predictable reasons. You can avoid them if you know what they look like.

  1. Generic templates with no building-specific reasoning - A short tick-box form can work for genuinely small and simple premises. For anything more complex, a generic template usually fails to show how you reached your conclusions. UK guidance recognises there are many valid formats, but expects the common factors to appear when you scrutinise an adequate assessment.
  2. No credible link between hazards, controls, and outcomes - You must show why existing measures work, and what you need to improve. A list of “issues” without a risk-based explanation does not demonstrate suitability.
  3. Poor treatment of vulnerable occupants and evacuation reality - If people need assistance to evacuate, you must address it. Housing-related guidance repeatedly stresses the need to consider disabled residents and how evacuation can be facilitated when simultaneous evacuation applies.
  4. No maintenance evidence - An assessment can only be “sufficient” if the safety measures remain effective. Modern expectations emphasise ongoing testing and maintenance regimes. For example, BS 9792 expects the FRA to determine whether systems and facilities for the fire and rescue service receive regular testing and maintenance by a competent provider.
  5. No review cycle - Fire risk assessment is not a one-off exercise. You need review triggers and a practical timetable, aligned to change in layout, use, occupancy, incidents, or degradation.

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A Practical Framework You Can Use to Build a Suitable and Sufficient Fire Risk Assessment

A structured methodology helps you prove completeness. UK guidance for fire risk assessment sets out a structured, step-based process and explains that the number of steps matters less than ensuring you address all relevant issues in a coherent way.

Use this as a practical structure, regardless of whether your premises is commercial, mixed-use, or residential with common parts. Your fire risk assessor should follow a structured approach that covers at least the following.

Step 1. Define the premises, scope, and dutyholders

Be explicit about:

  1. The premises covered (whole building, common parts, individual units if applicable).
  2. The occupancy and use (including any sleeping risk, care provision, or public access).
  3. The dutyholder structure, including who controls what. UK guidance notes that duties can fall on more than one person in premises with multiple occupiers and shared control.
  4. Interfaces. For mixed-use, you often need to align a non-housing approach for commercial areas with housing-specific expectations for residential parts. UK guidance recognises mixed-use may require reference to both non-housing and housing approaches.

Evidence you should include:

  1. Simple floor plans or references to current plans.
  2. A short statement of what is included and excluded.
  3. Any known constraints, such as phased works, decanting, or temporary measures.

Step 2. Identify people at risk, including people who need assistance

Document:

  1. Typical occupancy numbers and patterns.
  2. Lone working.
  3. Night-time occupancy and staffing, where relevant.
  4. People especially at risk, including mobility, sensory, or cognitive impairments.

In residential settings, you should also consider new and emerging duties around evacuation planning for residents who cannot self-evacuate. The Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 come into force on 6 April 2026 and introduce duties focused on residents with compromised ability to evacuate in specified residential buildings.

Step 3. Identify fire hazards and the realistic ignition scenarios

Cover:

  1. Ignition sources (electrical, cooking, smoking, hot works, plant rooms).
  2. Fuel sources (waste storage, storage rooms, furnishings, combustibles in risers).
  3. Oxygen enrichment and special hazards where applicable.
  4. Compartmentation weaknesses that could allow spread, including service penetrations.

Make this specific. For example:

If you have recurring bin store fires, do not just write “arson risk”. Record the history, the bin store construction, access control, detection coverage, and whether your current control measures match the pattern.

Step 4. Assess existing fire protection and means of escape against the building’s reality

This is where many assessments become non-credible. You must test the building’s “paper strategy” against what you see on site.

For higher-risk residential buildings in England, Fire Safety (England) Regulations 2022 expect specific building information and control measures, including floor plans, a single-page building plan, and clear wayfinding signage.

Also consider:

  1. Detection and alarm coverage and whether it supports the evacuation strategy.
  2. Emergency lighting.
  3. Escape route widths, travel distances, and final exits.
  4. Fire doors. In multi-occupied residential buildings above 11 metres, the regulations include annual best-endeavours checks of flat entrance doors and quarterly checks of communal fire doors, including self-closers.
  5. Smoke control. Record condition, obvious defects, and whether it still supports the fire strategy. BS 9792 gives practical prompts for this kind of recording.
  6. Firefighting facilities and access. BS 9792 expects the FRA to include details of systems and facilities available for fire and rescue service use, such as fire mains, hydrants, access, lifts, secure information boxes, smoke control, wayfinding signage, and high voltage signage and equipment.

If you have modern buildings, make sure you use the fire safety information handed over at completion. Approved Document B highlights that Regulation 38 fire safety information should give the responsible person enough information to understand and implement the fire safety strategy, maintain systems, and carry out an effective fire risk assessment.

Step 5. Assess fire safety management and competence

A suitable and sufficient fire risk assessment must reflect how the building actually runs.

Record:

  1. Who owns the fire safety role at senior level.
  2. Who checks that actions happen.
  3. Testing and maintenance arrangements and the quality of records.
  4. Training, drills, and resident communication where applicable.

In high-rise residential buildings, Fire Safety (England) Regulations 2022 require monthly routine checks of lifts for firefighters, evacuation lifts, and essential firefighting equipment, with reporting duties if faults cannot be rectified within 24 hours. That requirement changes what “sufficient” looks like for your management system, because you need a process and records to match.

Step 6. Judge risk and produce a prioritised action plan

Your action plan must do more than list defects. It should prioritise by life safety impact and urgency.

A practical structure is:

  1. Immediate. Items that present an intolerable risk or make evacuation unreliable.
  2. Short term. Items that materially reduce resilience, such as failed door closers or compromised compartmentation in key routes.
  3. Medium term. Improvements that reduce risk further or address foreseeable degradation.
  4. Ongoing. Recurring tasks like inspections, training cycles, and maintenance reviews.

Include:

  1. The specific location of the issue.
  2. The recommended control.
  3. Responsibility owner.
  4. Target timescale.
  5. Any dependencies, such as access to flats, contractor lead times, or intrusive opening-up.

Step 7. Record significant findings in a way that demonstrates adequacy

Your documentation is where suitability and sufficiency becomes provable.

At minimum, ensure you can show:

  1. The hazards you identified and how you controlled them.
  2. The fire protection measures you rely on and their condition.
  3. The evacuation strategy and why it fits the premises.
  4. Management arrangements and evidence that they operate.
  5. A clear action plan with ownership and dates.

BS 9792 provides practical prompts for documenting key areas, including firefighting facilities, secure information boxes, evacuation alert systems, wayfinding, and maintenance expectations. Those prompts help you record in a way that enforcement teams can follow.

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Residential Buildings: What Changes the “Suitable and Sufficient” Standard

Residential common parts bring extra scrutiny because evacuation depends heavily on passive protection and resident behaviour.

In England, Fire Safety (England) Regulations 2022 add specific duties that often feed into what a sufficient assessment should reference, including:

  1. Fire safety instructions that include the building’s evacuation strategy and reporting arrangements, displayed and provided to residents, with regular refresh cycles.
  2. Fire door information provided to residents, covering keeping doors shut, not tampering with self-closers, and reporting defects.
  3. Fire door check frequencies above 11 metres, with record keeping for attempted access.
  4. For high-rise residential buildings, floor plans, building plans, secure information boxes, wayfinding, and routine checks of firefighting lifts and equipment.

From April 2026, the Fire Safety (Residential Evacuation Plans) (England) Regulations 2025 introduce new expectations around resident evacuation planning in specified residential buildings, including building emergency evacuation plans and their review cycle.

If you manage blocks, your suitable and sufficient fire risk assessment should recognise these operational duties and confirm how you comply, because they directly affect residents’ life safety.

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How to Make Your Assessment “Audit-Ready” in One Pass

Use this practical quality check before you sign off the assessment.

  1. Does the assessment describe the premises so someone unfamiliar can understand it?
  2. Does it identify all relevant person groups, including those who need help to evacuate?
  3. Does it reflect the real evacuation strategy and the building’s actual condition?
  4. Does it cover compartmentation, fire doors, and smoke control where they matter?
  5. Does it confirm testing and maintenance regimes, and does it reference evidence?
  6. Does it contain a prioritised action plan with owners and timescales?
  7. Does it state review triggers and a review schedule?

If you cannot answer “yes” to all seven, you should treat the assessment as incomplete.

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FAQs: Suitable and Sufficient Fire Risk Assessment

1) Who must complete a suitable and sufficient fire risk assessment?

In England and Wales, the responsible person must complete it under Article 9 of the Fire Safety Order. In many buildings, more than one party can hold duties where control is shared.

2) What makes a fire risk assessment “not suitable and sufficient”?

Common failures include generic content, missing vulnerable occupant considerations, no credible evacuation reasoning, weak evidence of maintenance, and no actionable plan with ownership and timescales. UK guidance recognises adequacy depends on judgement, but expects common factors to appear in adequate assessments.

3) Do you need to record significant findings?

Yes in many cases, including where organisational thresholds apply or where premises fall under certain regulatory controls. UK guidance explains that significant findings should indicate measures taken and measures to be taken for compliance.

4) How often should you review a suitable and sufficient fire risk assessment?

Review whenever risk factors change, and at regular intervals even without change. Use triggers such as layout change, occupancy change, incidents, recurring defects, or changes in fire safety systems. In residential settings, some evacuation plan duties also operate on a 12-month review cycle.

5) Does a suitable and sufficient fire risk assessment require a site visit?

For most premises, yes. Desktop-only assessments rarely provide enough evidence on compartmentation, fire doors, escape routes, and management practices. The more complex the building, the more site verification matters.

6) What documents should you keep to prove sufficiency?

Keep the assessment, action plan, evidence of completion of actions, maintenance and testing records, training records, resident communications where applicable, and relevant fire safety information. Approved Document B highlights the purpose of Regulation 38 information as enabling effective fire risk assessment and ongoing management.

7) What is the link between Fire Safety (England) Regulations 2022 and your fire risk assessment?

The regulations impose specific operational duties that directly affect life safety. Your assessment should reflect them and confirm how you comply, including resident instructions, fire door information, and fire door checking regimes.

8) What is “best endeavours” for annual flat entrance door checks?

Government guidance explains that responsible persons must use best endeavours to check flat entrance fire doors at least every 12 months and communal doors at least every 3 months in relevant buildings above 11 metres.

9) Do you need to reference evacuation alert systems, secure information boxes, and wayfinding?

In relevant buildings, yes. BS 9792 expects the FRA to include, as a minimum, details of systems and facilities for the fire and rescue service, including secure information boxes, evacuation alert systems, smoke control, and wayfinding signage where applicable.

10) Can you combine health and safety risk assessment with fire risk assessment?

You can, but UK guidance notes this tends to be realistic only in very small premises. Most organisations keep them separate because they require different skills and depth.

11) Does “suitable and sufficient” mean you must follow one specific template?

No. UK guidance recognises there is no single correct method, but expects adequate assessments to address common prerequisites and to support risk-proportionate decisions.

12) Does using a British Standard guarantee compliance?

A standard can give you a strong benchmark and structured method. Compliance with a standard does not remove legal duties, but it can make your approach easier to justify, especially where the standard prompts you to record the right information and evidence.

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Conclusion: How You Demonstrate a Suitable and Sufficient Fire Risk Assessment

You demonstrate a suitable and sufficient fire risk assessment when you show a clear line from real building risk, to appropriate controls, to documented evidence and deliverable actions. Start with the legal duty under Article 9. Build a structured assessment that fits your premises. Record significant findings with enough clarity that a third party can follow your reasoning. Then prove that your management system keeps the precautions effective over time.

If you want to reduce enforcement risk and improve resident and occupant safety, treat your suitable and sufficient fire risk assessment as a living management tool. Keep it evidence-led, specific to your building, and backed by a prioritised action plan that you actually complete.

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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.

Get in touch with us today to arrange a no-obligation consultation - please call 020 4534 3130.

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For further information on all aspects of this service see the collection of articles in our blog.

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For further information on Fire Risk Assessment, Retrospective Fire Strategies, FRAEWs or advice in respect of your obligations as a building owner, developer or manager, please contact :

Sarah Taylor

Sarah Taylor

Business Support Manager

Building Surveying

London