Understanding PAS9980 – FRAEW Guidance

In the wake of the Grenfell Tower tragedy, the UK introduced a wave of reforms to strengthen fire safety in residential buildings. A cornerstone of these reforms is PAS9980:2022 – a comprehensive code of practice for conducting Fire Risk Appraisals of External Wall construction (FRAEWs). Understanding PAS9980 is essential for developers, building owners, managing agents, fire engineers, and dutyholders tasked with compliance under the Building Safety Act 2022.

This article delves into the structure, methodology, and practical application of PAS9980, explaining how FRAEWs are carried out, the criteria for assessing risk, and the broader implications for building safety management. We will explore key concepts, risk factors, and the importance of engaging competent professionals in undertaking these appraisals.

What Is PAS9980?

PAS9980:2022 is a publicly available specification published by the British Standards Institution (BSI), commissioned by the UK Government. It sets out a consistent methodology for competent professionals to appraise the fire risk of external wall construction and cladding systems on existing multistorey, multi-occupied residential buildings.

The document does not prescribe specific remedial actions. Instead, it provides a structured approach for assessing whether the construction of external walls contributes to the overall fire risk and whether that risk is tolerable or requires mitigation.

PAS9980 supports the government’s policy of moving away from the indiscriminate use of EWS1 forms and promotes a more proportionate, risk-based approach to external wall assessments.

Why Was PAS9980 Introduced?

The introduction of PAS9980 aimed to restore confidence in high-rise residential buildings by shifting the emphasis from blanket cladding removal to evidence-based risk assessment. Following Grenfell, widespread uncertainty led many lenders and insurers to demand intrusive surveys and costly remediation even where buildings posed little real fire risk.

The government recognised that not all buildings with combustible materials required remediation. PAS9980 offers a structured framework to enable competent professionals to justify when mitigation may not be necessary.

What Buildings Does PAS9980 Apply To?

PAS9980 applies to:

Existing buildings that are multi-storey, multi-occupied residential premises, including conversions and mixed-use buildings.

It is not intended for new buildings under design or construction, although the principles may offer guidance for refurbishment projects.

The document is also relevant where existing buildings are undergoing a change of use, such as office-to-residential conversions. In such cases, a FRAEW may form part of a broader fire safety strategy.

Who Can Carry Out a FRAEW?

A Fire Risk Appraisal of External Walls under PAS9980 must be carried out by a competent professional with:

Suitable qualifications in fire engineering, architecture, or building surveying.

Extensive experience in assessing external wall construction.

An understanding of fire spread mechanisms and building design principles.

The professional must have the ability to assess materials, cavity barriers, fixings, and the overall configuration of the wall system. The guidance strongly advises that only those with sufficient expertise and independence should undertake these appraisals.

Understanding Key Principles of PAS9980

Understanding PAS9980 involves getting to grips with five fundamental principles that underpin every FRAEW:

1. Risk-Based, Not Compliance-Based

PAS9980 does not set mandatory standards for external wall construction. Instead, it requires assessors to apply a risk-based methodology, considering the likelihood of fire spread and its potential consequences.

This approach encourages proportionate decision-making based on:

The height and use of the building.

The materials used.

Occupant vulnerability.

Existing fire safety measures.

2. Holistic Fire Risk Context

The appraisal must not be conducted in isolation. PAS9980 emphasises that external wall risk should be considered within the context of the building’s overall fire strategy, including:

Means of escape.

Fire detection and alarm systems.

Compartmentation.

Management arrangements.

A FRAEW should complement the wider Fire Risk Assessment (FRA) required under the Regulatory Reform (Fire Safety) Order 2005 and updated by the Fire Safety Act 2021.

3. External Wall Systems (EWS) as a Whole

Assessors must evaluate the entire external wall system, including:

Cladding materials (e.g. ACM, HPL, render, terracotta, metal panels).

Insulation types.

Fire-stopping and cavity barriers.

Fixings and substructure.

Spandrel panels and balcony details.

No single material defines the risk. Instead, the interplay between components and their potential to propagate fire is critical.

4. Use of Risk Ratings

The FRAEW should culminate in a risk rating, guiding stakeholders on whether mitigation is needed. The risk levels defined in PAS9980 are:

Low Risk – No action required.

Medium Risk – Risk tolerable but could be improved.

High Risk – Remediation or significant mitigation strongly recommended.

This rating enables dutyholders to make informed, proportionate decisions and avoid unnecessary interventions.

5. Mitigation Measures Over Blanket Remediation

Where risks are identified, assessors are encouraged to explore mitigation options short of full remediation. These may include:

Installation of sprinklers.

Improved fire detection and alarm systems.

Enhanced evacuation procedures.

Fire wardens or waking watches (though seen as interim only).

The guidance steers professionals away from a default “remove and replace” mentality and instead promotes sensible, building-specific solutions.

The PAS9980 Five-Step Methodology

Understanding PAS9980 requires familiarity with its structured five-step FRAEW process:

Step1: Information Gathering

Review as-built drawings, O&M manuals, fire strategies.

Obtain intrusive survey results (if necessary).

Identify materials and construction types.

Step2: Assessment of Risk Factors

Consider combustibility, fire spread potential, and presence of cavity barriers.

Evaluate the configuration of the façade, height of the building, and occupancy profile.

Step3: Consideration of Mitigating Measures

Identify existing or potential compensatory features (e.g. sprinklers, fire alarms).

Assess management procedures and maintenance practices.

Step4: Risk Rating Assignment

Use professional judgement to determine an overall risk rating.

Provide clear justification for conclusions.

Step5: Reporting and Recommendations

Issue a clear, structured report.

Include visual records, findings, and any proposed actions.

Recommend where further investigation or remediation is necessary.

PAS9980 and the EWS1 Form

While PAS9980 and the EWS1 form are related, they serve different purposes:

PAS9980 is a technical framework for conducting FRAEWs.

The EWS1 form is a lender-facing document signed by a competent professional to confirm whether external wall materials require further review for valuation purposes.

PAS9980 provides the evidence base that supports an EWS1 form, but not all buildings require EWS1 forms. For instance, buildings under 11m in height typically fall outside the scope, unless specific risk features exist.

PAS9980 and the Building Safety Act 2022

Understanding PAS9980 also means recognising its role within the broader regulatory landscape. Under the Building Safety Act 2022, the Accountable Person for higher-risk buildings (18m+ or 7 storeys+) must maintain a Safety Case demonstrating how fire and structural risks are managed.

A FRAEW conducted under PAS9980 is likely to form a key part of the Safety Case File and will support the building’s ongoing Golden Thread of Information.

Implications for Dutyholders and Managing Agents

Building owners, managing agents, and leaseholder-controlled companies must:

Understand when a FRAEW is appropriate.

Appoint qualified professionals to carry out PAS9980-compliant assessments.

Avoid unnecessary surveys or remediation unless risk-based evidence supports it.

Communicate findings clearly to residents and stakeholders.

For dutyholders, PAS9980 offers clarity and confidence, enabling proportionate risk management that avoids panic-driven overcorrection.

Understanding PAS9980 - Common Misconceptions

1. “All combustible materials must be removed.”
Not necessarily. The focus is on risk, not blanket material bans.

2. “PAS9980 applies to every building.”
No – it’s intended for multi-occupied residential buildings and not for single dwellings or new builds.

3. “If my building passes PAS9980, I don’t need an FRA.”
Incorrect – the FRAEW is just one part of the overall fire risk assessment required under fire safety legislation.

Conclusion - Understanding PAS9980

Understanding PAS9980 is vital for anyone involved in managing or maintaining multi-occupied residential buildings. It marks a pivotal shift toward proportionate, risk-based fire safety practices, ensuring external wall assessments are rooted in sound evidence and professional judgement.

By using the PAS9980 framework, building owners and professionals can reduce unnecessary interventions, protect resident safety, and comply with legal obligations under the Building Safety Act and Fire Safety Order. However, success depends on competent assessors, clear reporting, and a collaborative approach to building safety.

Need help conducting a PAS9980-compliant FRAEW?

Anstey Horne’s expert fire risk consultants and chartered surveyors are here to help. We deliver independent, proportionate assessments you can trust – across residential, commercial, and mixed-use buildings.

We provide specialist assessment and mitigation advice on buildings that fail to meet the required safety standards.

This service includes the procurement of a specialist design team for the full remediation of the external façade if required. The advice we provide is backed by specific professional indemnity insurance to undertake this work.

To commission an FRAEW survey or Fire Risk Assessment (FRA) please call 020 4534 3130.

For further information on FRAEW Surveys, PAS9980 or EWS1 forms please get in touch.

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

To commission an EWS1 Survey, an FRAEW or a Fire Risk Assessment (FRA) please call 020 4534 3130.

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