• October 18, 2019

    What is the Regulatory Reform (Fire Safety) Order 2005?

    The Regulatory Reform (Fire Safety) Order 2005, or ‘RRO’ for short, was introduced to provide a minimum safety standard for all non-domestic buildings. It designates responsibility for fire safety to a specific person or persons, depending on the premises.

    Essentially it ensures that any person with some level of control in a premises takes reasonable steps to reduce the risk of fire. That same person also needs to do everything possible to make sure that people can escape safely from the building if a fire breaks out.

    Those responsible for abiding by the RRO must carry out specific fire safety duties. This includes conducting a fire risk assessment and taking resulting actions to protect the occupants of their building. If they do not do this they risk penalties ranging from fines to a prison sentence.

    emergency exit sign lit up in dark

    How is the Regulatory Reform (Fire Safety) Order 2005 different to previous fire safety regulations?

    Prior to the RRO 2005, fire safety in the United Kingdom was outlined by some seventy pieces of fire safety legislation.

    The most notable of these was the Fire Precautions Act 1961 and the Fire Precautions (Workplace) Regulations 1997/1999. In 2001 it was decided that the regulations needed to become centralised to a single piece of legislation, in order to simplify the expected conduct outlined within it.

    In comparison to the previous legislation, the RRO 2005 places greater emphasis on fire prevention in all non-domestic premises. This includes premises used within the voluntary sector as well as premises used by self-employed persons separate from their home.

    The key difference is that it focuses on “all non-domestic premises”. Previous legislation focused on workplace environments, whereas the RRO 2005 includes any premises with a large volume of people working and/or visiting.

    The RRO 2005 has since been significantly strengthened by the Fire Safety Act 2021 and Building Safety Act 2022, which have clarified and expanded the duties of the Responsible Person, particularly in multi-occupied residential buildings.

    For example, the Fire Safety Act 2021 now explicitly confirms that the Responsible Person’s duties for multi-occupied residential buildings cover the structure, external walls (including cladding, balconies, and windows), and individual flat entrance doors, as explained by the National Fire Chiefs Council (NFCC). These amendments were a direct response to the critical lessons learned from the Grenfell Tower tragedy, ensuring that a building’s entire construction and composition are properly included in the fire risk assessment process.

    Furthermore, in England, the Fire Safety (England) Regulations 2022 introduced specific, actionable requirements, particularly for high-rise residential buildings, covering items like the provision of secure information boxes for fire services, monthly lift checks, and annual checks of flat entrance fire doors, as detailed by UK Government guidance. This demonstrates an ongoing shift towards greater accountability and a more holistic view of fire risk management, extending beyond general workplace safety to address the entire lifecycle and construction of a building. Responsible Persons managing multiple occupancy premises, such as property management firms, must be fully aware of these new regulations.

    Despite a long-term downward trend in total fires, the sheer number of incidents still highlights the ongoing risk. The latest UK fire statistics reveal that Fire and Rescue Services attended 38,375 building fires (which includes non-domestic premises) in England, underlining the persistent need for robust compliance and effective fire safety measures. Worryingly, the statistics also show a rise in fire false alarms due to apparatus, reaching 183,115 in the same period, emphasising the crucial nature of professional fire alarm system servicing and maintenance to ensure systems are reliable and minimise disruption.

    Which types of premises does the Regulatory Reform (Fire Safety) Order 2005 apply to?

    As the RRO 2005 covers all non-domestic premises, there are now a wide range of building types that are subject to the order. These include:

    Offices and shops

    • Offices and retail premises (including individual areas within larger premises such as within a shopping centre). Industry-Specific Guide. For businesses in this sector, understanding the nuances of security is also important; find more information on securing your commercial space in our guide to business security packages compared.

    Factories and warehouses

    • Factories and warehouse storage premises. Industry-Specific Guide. Implementing robust fire and security for large-scale operations, especially in logistics and manufacturing, often requires integrated systems for complete protection.

    Sleeping accommodation

    • Applies to any premises where the main purpose is to provide sleeping accommodation. This includes, but is not limited to; hotels, guest houses, B&Bs, hostels, holiday accommodation, HMO properties and sheltered housing. This category does not include premises providing general care, health care and places of custody. Industry-Specific Guide.

    Residential care premises

    Educational premises

    • Educational facilities including pre-school premises through to university campuses. Excludes student residential areas. Industry-Specific Guide. | Fire safety in schools 2020 guide For those responsible for these sites, fire safety, alongside effective lockdown procedures, is paramount, which is why we offer dedicated solutions for the education sector.

    Small and medium places of assembly

    • This includes restaurants and cafes, community centres, libraries, churches and other places of worship, small public houses, clubs – essentially meeting places that can accommodate up to 300 people. Industry-Specific Guide.

    Large places of assembly

    • Premises designed to accommodate upwards of 300 people, e.g. shopping centres, large night clubs, conference centres, museums, libraries, churches and other places of worship. Industry-Specific Guide.

    Theatres and similar premises

    Open-air events and venues

    • Including but not limited to, theme parks, zoos, sporting events, fairgrounds and county fairs. Industry-Specific Guide.

    Health care premises

    Transport facilities

    • Any transport facility or terminal including airports, train stations, bus stations, transport tunnels and ports. However, this excludes the means of transport itself. Industry-Specific Guide.

    Animal premises

    • Any equine establishment, stables, livery yards of other premises housing animals. Not inclusive of zoos (see open-air events and venues). Industry-Specific Guide.

    A guide is also available for providing a Means of Escape for Disabled People, which you can find here.

    Red and Yellow Fire Extinguisher

    Who is responsible for meeting the standards set out in the RRO?

    Under the regulations set out in the RRO 2005, anyone who has control of a premises or anyone who has a degree of control over specific areas or systems may be considered a ‘responsible person’. This includes:

    • The employer for the parts of a premises an employee may enter
    • The owner or managing agent for shared parts of the premises
    • The occupier, such as someone who is self-employed or voluntary organisations should they have any control
    • Any other person who has some control over a part of the premises

    The Building Safety Act 2022 introduced significant amendments to the RRO 2005, effective from 1 October 2023, specifically strengthening the requirements placed on the Responsible Person for all buildings regulated by the Order. Crucially, all Responsible Persons must now formally record their fire risk assessment in full, regardless of the size or number of employees, which was a change from the previous rule which only required recording significant findings for premises with five or more employees. They must also record the full name and organisation of any person appointed to undertake or review the fire risk assessment. The legislation also demands greater cooperation and coordination between multiple Responsible Persons in the same premises to ensure a unified approach to safety, and a chain of fire safety information must be maintained and shared when a Responsible Person hands over control, for example, between a landlord and a retail tenant.

    Furthermore, new duties now include the need to record fire safety arrangements, demonstrating how fire safety is managed and providing a written fire safety policy. The Responsible Person for multi-occupied residential buildings must also provide residents with detailed, easily understandable fire safety instructions, including the evacuation strategy and the risks identified in the fire risk assessment. These enhanced duties underscore the legal and ethical obligation to ensure fire safety, and failure to comply can have severe consequences, including unlimited fines for some offences, as stipulated in the enforcement changes brought by the Building Safety Act 2022.

    What are the main rules set out in the RRO?

    As an absolute minimum you must by law:

    • Carry out a fire risk assessment to identify any potential dangers and risks on your premises
    • Consider anybody who may be especially at risk. For example, somebody with a physical disability
    • Completely remove or reduce the risk from fire as far as is reasonably possible, whilst providing general fire precautions to deal with any remaining risk
    • Take further measures to make sure there is protection for the storage of any flammable and/or explosive materials
    • Create a plan to deal with any emergency and, if 5 or more employees have access to the area under your responsibility, keep and record your findings
    • Review and edit your findings when necessary

    Understanding these core rules is fundamental to a building’s operation. Beyond the initial assessment, ensuring you have the right systems in place is critical. For instance, the maintenance of fire safety systems, like fire alarms, is a continuous legal duty; read about the future of maintenance in fire safety. Integrating systems can also enhance your compliance and efficiency, which is a core part of our office fire and security solutions.

    What is a fire risk assessment?

    A fire risk assessment is a step by step process that must be carried out by the owners of all non-domestic premises. As a result, the responsible person can gain a full understanding of the current level of safety within the building and identify where improvements need to be made. The five steps below summarise how a risk assessment is carried out.

    Fire hazard cigarette lighter

    Step 1 – Identify any hazards within your premises

     

    You need to identify:

    • Any source of ignition such as naked flames, heaters and commercial processes
    • Sources of fuel i.e. waste build-up, textiles, display materials and overstocked products
    • Sources of oxygen including air conditioning units and medicinal or commercial oxygen supplies

    Elderly people most at risk from fire

    Step 2 – Identify the people at risk

    You need to identify any persons that are especially at risk, such as:

    • People working in close proximity to fire dangers
    • People working alone and/or in isolated areas
    • Children and parents with babies
    • The elderly and people with physically inhibiting disabilities

    fire hazard cigarette butts

    Step 3 – Evaluate, remove, reduce and protect from risk

    You need to evaluate the level of risk in your premises. Should you find any fire hazards, they need to be removed or reduced where possible. For example, you can:

    • Make sure you separate any potentially flammable materials from sources of ignition
    • You can replace the flammable materials with less-flammable materials entirely, or better yet flame-retardant material
    • Have a safe smoking policy

    General fire precautions you should take

    It is not possible to give in-depth guidance for the precautions that should be taken in each type of premises. However, these are the minimum precautions that you should take.

    A fire detection and warning system

    • There must be a suitable fire detection system in place. This depends on the type of premises but can range from a shouted warning to electrical warning systems. You can find out more about the categories of fire alarms with our handy guide.

    • It must be able to warn people in ALL circumstances

    A means of extinguishing small fires

    • It may be suitable to have a multipurpose extinguisher with a guaranteed shelf life
    • You should have one fire extinguisher for every 200m² of your premises

    Safe routes for people escaping the premises

    Ideally, there will be more than one escape route for each part of the building, although it is understood that this is not always possible. In either case, you must ensure that effective emergency signage is provided to guide those escaping a fire. Please follow our emergency signage guide here.

    Suitable fire exit doors

    • All fire safety exit doors on the escape route must be usable without a key or any specialist knowledge
    • In a premises used by a large volume of people, doors on the escape route should be usable by push (panic) pads or push bars

    All small and simple premises may be able to satisfy these standards with relative ease. However, you should still evidence any precautions you have taken.

    A crucial element of risk reduction in Step 3 is the effective use of **Passive Fire Protection (PFP)**. PFP measures, such as fire stopping and sealing and certified fire doors, are built into the structure of a building to contain fire and smoke, helping to preserve escape routes and reduce the overall damage. This is a non-negotiable part of compliance for commercial premises, as PFP is what allows a building to be compartmented, slowing the spread of fire and giving occupants the necessary time to evacuate safely, which is why we created a comprehensive guide to Passive Fire Protection. For multi-occupied residential buildings over 11 metres in height, the Fire Safety (England) Regulations 2022 mandate **quarterly checks on communal fire doors** and **annual checks on flat entrance fire doors**, highlighting the critical role these elements play in saving lives.

    Fire Extinguisher on Stand

    Step 4 – Record, plan, inform, instruct and train

    It’s time to record your findings and actions. Take note of any dangers and people specifically at risk in steps 1 and 2. You should also record what you did in step 3 to rectify or reduce potential fire hazards. A basic plan can help you to do this.

    You will also need an emergency plan. This should include any action you may take in the event of a fire. It should also document the fire safety instructions you have given to staff, guests, volunteers or any other persons regularly on the premises.

    All persons should receive adequate information and training about the potential risks on the premises relative to their position. For example, a fire marshal will need significantly more training than general staff in order to carry out their duties. You can find more practical guidance on how to train fire safety champions within your team.

    fire risk assessment plan

    Step 5 – Review and Revise

    You should always make sure that your fire risk assessment is up to date. Your assessment should be re-examined if for any reason you believe it to be no longer valid.

    For example, there may have been changes made to the premises or a relevant incident that suggests there is a change to the level of risk at your premises. This may include:

    • A change in the number of persons regularly on the premises
    • The arrival of a large amount of extra stock
    • New staff starting or different shift types being introduced

    Maintaining a current fire risk assessment is vital, and the introduction of **Section 156 of the Building Safety Act 2022** formally requires the Responsible Person to keep an accurate, ongoing record of their fire safety arrangements and the fire risk assessment itself, fostering a culture of continuous safety review. This review process should also consider modern security threats; for advice on managing access alongside fire safety, see our guide on managing access control in large commercial premises.

    Enforcement of the RRO

    The main agency responsible for enforcing fire safety regulations are the fire authorities. Due to the sheer number of premises, they have to be very specific when it comes to spending resources. Therefore, premises with a particularly high risk, such as care homes for the elderly, have yearly inspections.

    However, regardless of the perceived level of risk, the fire authorities will carry out investigations where there have been a number of complaints and in areas where poor fire safety management is discovered.

    Consequences of non-compliance

    Other than in the most serious cases, the fire authority will usually work with you in order to achieve a satisfactory level of safety. They will do this by providing practical advice and/or a formal notice.

    If a genuine risk to life is discovered, the fire authority may issue a notice preventing the premises being used for certain activities such as cooking or sleeping. They may go onto ban use of the building entirely.

    In all cases, you will have the right to appeal. This can be done informally by speaking with a fire safety manager to agree on a different means of meeting satisfactory fire safety. Failing that, a formal appeal may take place through the magistrate’s court.

    For serious offences, where there is a genuine disregard for life, you may be fined and/or imprisoned. Minor penalties can include a fine of up to £5,000. Major penalties meanwhile range from unlimited fines to a 2-year prison sentence.

    It’s important to note that changes brought by the **Building Safety Act 2022** have increased the severity of potential penalties. The fine for several key offences, such as intentionally impersonating an inspector or failing to comply with specific inspector requirements without reasonable excuse, has been increased to an **unlimited fine** after October 2023. This change is a clear indication that the government is taking a much tougher stance on non-compliance, particularly where it involves misleading the authorities or deliberately failing to meet fire safety obligations. For businesses, being able to demonstrate a clear commitment to fire safety not only saves lives but also protects commercial interests and your standing with your insurer, as we detail in our article on how fire safety impacts your commercial insurance premiums.

    Who should carry out a fire risk assessment?

    This depends mainly on how complex the business or organisation is.

    If your business or organisation is relatively small, it is possible for you to carry out a fire risk assessment yourself. If you are planning on carrying out your own assessment, please refer to the industry-specific guides earlier in the article.

    For larger more complex businesses, you should contact an expert such as BusinessWatch to carry out the assessment. The fire authority will not carry out an assessment for you. Their responsibilities lie in ensuring your assessment was carried out correctly.

    Engaging a competent, professional fire safety provider is the best way to ensure full legal compliance, especially for sectors such as leisure or factory environments that have unique and complex fire risks.

    If you would like advice or an expert to aid you during your assessment, please contact us or apply for a free quote. Alternatively, visit our Fire Risk Assessments page to find out more about our services.