When is a FRAEW Required? Trigger Events and Risk Factors

Understanding when a Fire Risk Appraisal of External Walls (FRAEW) is required is critical for building owners, managing agents, fire risk assessors, and surveyors navigating compliance under the Fire Safety Order and Building Safety Act. Triggered by post-Grenfell reforms, the need for a FRAEW hinges on specific building characteristics, fire risk factors, and the presence of combustible materials within external wall systems.

This guide examines the events and risk factors that trigger the need for a FRAEW, offering clarity through PAS 9980:2022, relevant legislation, and practical considerations.

What Is a FRAEW?

A FRAEW is a structured risk-based assessment of the external wall construction of an existing multi-occupied residential building. The purpose is to determine the risk to occupants from fire spreading over or within the external walls. It assists in establishing whether remediation or mitigation measures are necessary, especially in cases where combustible materials, poor workmanship, or inadequate fire stopping may compromise safety.

PAS 9980:2022 provides the national methodology for conducting a FRAEW. It guides competent professionals on evaluating external wall risks proportionately and consistently.

Key Legislative Drivers

The requirement for a FRAEW primarily stems from amendments made by the Fire Safety Act 2021 to the Regulatory Reform (Fire Safety) Order 2005. These amendments confirmed that the external walls of a building - including cladding, balconies, and attachments - fall within the scope of a fire risk assessment.

Under the Fire Safety Order, the “Responsible Person” must ensure that fire risk assessments include external walls where relevant. This legal duty follows a risk-based approach, not a prescriptive one, so you only need a FRAEW if there is a justifiable concern or a trigger event.

PAS 9980 aligns with this regulatory framework by enabling fire engineers and competent assessors to determine whether a building's external walls present an unacceptable life safety risk.

When Is a FRAEW Required?

A FRAEW is required when a competent fire risk assessor deems that the external wall construction of an existing block of flats may contribute to unacceptable fire risk. This typically applies to buildings that exhibit one or more of the following trigger events or risk factors:

1. Presence of Combustible Materials in the External Wall System

Combustible cladding (e.g. ACM, HPL, timber)

Combustible insulation (e.g. PIR, PUR, EPS)

Timber battens or combustible membranes in the cavity

Plastic-based spandrel or infill panels

Where combustible materials are suspected or confirmed, a FRAEW is often required unless the quantity is demonstrably negligible.

2. Partial or Full Cladding of the Façade

If a building is partially or fully clad, especially in combustible materials, the risk of vertical fire spread is higher. The extent, continuity, and layout of the cladding system are vital considerations.

3. Building Height and Storeys

Buildings ≥18m (or seven storeys) are inherently higher risk

Buildings <18m may still require a FRAEW if combustible materials are present, or other aggravating factors exist

Fully or partially clad buildings below 11m can also present unacceptable risk

4. Building Configuration and Use

Buildings likely to require a FRAEW include:

Purpose-built blocks of flats (any height)

Student accommodation

Sheltered or specialist housing

Converted buildings with multiple dwellings

Mixed-use buildings (e.g. flats above commercial premises)

5. Fire Risk Assessor Recommendation

During a fire risk assessment (FRA), if the assessor identifies uncertainty or concern over the external wall system - especially regarding materials, fire stopping, or cavity barriers - a FRAEW may be recommended.

6. Mortgage Lender, Valuer, or Insurer Request

Mortgage providers and insurers often request evidence of a FRAEW before proceeding with transactions involving flats in buildings where combustible cladding or unclear materials are present.

7. Visual Signs of Poor Workmanship or Degradation

Indicators that could prompt a FRAEW include:

Warped or deteriorating cladding

Poorly installed or missing cavity barriers

Incomplete fire stopping

Visible signs of water ingress or corrosion affecting façade elements

8. Historic Renovations or Recladding Works

If a building underwent recladding or refurbishment - particularly between 2000 and 2017 - it may feature legacy systems using combustible materials. Absence of documentation or post-works verification often triggers a FRAEW.

9. Fire Strategy Issues or Change in Evacuation Strategy

Where the fire strategy is unclear or has changed (e.g. from "stay put" to simultaneous evacuation), a FRAEW helps assess whether the external wall system supports the chosen approach.

10. External Features Increasing Fire Spread Potential

Elements like balconies, decking, planters, timber screens, or external services can increase fire risk if combustible or poorly installed. These warrant consideration within a FRAEW.

When a FRAEW Is Not Required

Not every building requires a FRAEW. Scenarios where it is typically not needed include:

Buildings with traditional masonry or concrete walls with no cladding or cavities

External wall systems confirmed as entirely non-combustible (e.g. A1/A2-s1,d0 materials)

Low-rise buildings with no façade coverage and limited fire loading

Structures with comprehensive supporting documentation and inspection records demonstrating negligible risk

A competent fire risk assessor may determine that the wall poses no additional fire risk, thereby negating the need for a full FRAEW.

FRAEW vs EWS1 Form

You should not treat the FRAEW as a substitute for the EWS1 form, which serves primarily for valuation purposes. However, a FRAEW often provides the technical foundation that informs an EWS1 assessment. Mortgage valuers frequently require a FRAEW to justify a B1 or B2 rating on the EWS1.

Who Can Carry Out a FRAEW?

Only competent professionals - typically chartered fire engineers, fire safety consultants, or accredited surveyors - should undertake FRAEWs. PAS 9980 sets out expected competencies including:

Experience with façade systems and fire dynamics

Understanding of cavity barrier installation

Familiarity with reaction-to-fire classifications (e.g. Euroclass ratings)

Ability to evaluate fire risk contextually within a building's fire strategy

FAQs - When is a FRAEW Required

What does PAS 9980 say about when a FRAEW is needed?

PAS 9980 provides a structured five-step methodology for determining when a FRAEW is required. It emphasises risk-based decision-making and professional judgement over prescriptive rules.

Can a low-rise building need a FRAEW?

Yes. While height is a factor, other elements like combustible cladding, poor fire stopping, and façade complexity may necessitate a FRAEW on low-rise buildings.

Does the presence of cavity barriers eliminate the need for a FRAEW?

Not necessarily. Even with cavity barriers, the presence of combustible materials or poor workmanship may still create fire spread risks that require assessment.

Is a FRAEW mandatory?

You are not legally required to undertake a FRAEW unless the building’s fire risk assessment identifies the need for one. However, failing to do so when necessary may result in regulatory enforcement.

Who pays for a FRAEW?

Typically, the building owner or managing agent commissions and funds the FRAEW. In some cases, costs may be recoverable through the Building Safety Fund or service charges.

Key Takeaways - When is a FRAEW Required

A FRAEW is required when there is potential for fire to spread via external walls due to combustible materials, inadequate fire barriers, or façade configuration.

PAS 9980 provides the formal methodology for assessing external wall fire risk in existing residential buildings.

Trigger events include cladding, building height, fire strategy changes, poor workmanship, and lender or fire risk assessor requests.

Competence is essential - only trained professionals should complete FRAEWs.

A FRAEW is a life-safety tool, designed to inform the fire risk assessment and guide proportionate remedial actions.

Need a FRAEW Survey?

If you’re responsible for a residential building and unsure about the safety of its external walls, speak to a competent FRAEW provider. At Anstey Horne, our expert team of fire engineers and surveyors deliver independent, proportionate, and fully compliant FRAEW Surveys.

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

If you'd rather we called you, or for further information on FRAEW Surveys please fill in our contact form and we will be in touch.

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