Fire Safety · Mandatory · Pre-Construction
Fire Risk Assessment — Construction Site
A fire risk assessment specific to the construction site environment.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. RRO 2005 Art 9 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Legal basis | Regulatory Reform (Fire Safety) Order 2005 (RRO) Article 9 — duty to carry out a fire risk assessment |
| Recording requirement | Building Safety Act 2022 s.156 (commenced October 2023): a full written fire risk assessment is now required for ALL non-domestic premises — the previous exemption for premises with fewer than 5 employees has been removed |
| Fire Safety Act 2021 | Clarified that the RRO applies to the structure, external walls, and flat entrance doors of multi-occupied residential buildings — resolving ambiguity exposed by the Grenfell Tower inquiry |
| 5-step process | Identify fire hazards, identify people at risk, evaluate/remove/reduce/protect, record/plan/inform/train, review |
| Construction site risk | Changing risk profile through phases, hot works, timber frame construction, arson, temporary accommodation — FRA must be reviewed at every phase transition |
| Latest standard | BS 8214:2026 published 31 March 2026 — provides updated guidance on fire risk assessment methodology and documentation |
1. Fire Risk Assessment
The fire risk assessment is the foundation of fire safety on any construction site or in any non-domestic premises. Article 9 of the Regulatory Reform (Fire Safety) Order 2005 (RRO) places a duty on the responsible person to carry out a suitable and sufficient assessment of the risks to which relevant persons are exposed for the purpose of identifying the general fire precautions needed to comply with the Order. The assessment must be recorded, kept under review, and revised whenever there is reason to suspect it is no longer valid or there has been a significant change in the matters to which it relates.
The Building Safety Act 2022, section 156, made a critical change to the recording requirement. Prior to its commencement in October 2023, the RRO only required the fire risk assessment to be recorded in writing where the employer had five or more employees. Section 156 removed that threshold entirely. A full written fire risk assessment is now required for all non-domestic premises regardless of the number of employees. This means every construction site, every office, every warehouse, and every retail unit must have a documented fire risk assessment.
On construction sites, the fire risk profile changes continuously as the project progresses through different phases. During groundworks, the primary hazards may be fuel storage and temporary heating. During the structural frame, timber frame construction presents an extreme fire risk. During fit-out, the accumulation of combustible materials, the use of hot works, and the installation of fire protection systems (which are not yet operational) all create significant hazards. Arson remains a persistent threat throughout all phases. The fire risk assessment must reflect these changing conditions and be reviewed at each phase transition.
BSA 2022 s.156: full written record now required for all premises
Since October 2023, the Building Safety Act 2022 s.156 has removed the previous exemption that allowed premises with fewer than 5 employees to avoid recording their fire risk assessment in writing. A full written fire risk assessment is now a legal requirement for every non-domestic premises, regardless of size or number of employees. There is no longer any lawful basis for not having a documented fire risk assessment. Failure to comply is a criminal offence under the RRO.
2. Required Content
A compliant fire risk assessment must cover each step of the five-step process and record the findings, the controls in place, and the actions required. The following table sets out the required content for a fire risk assessment on a construction site or non-domestic premises.
| Item | Detail |
|---|---|
| Premises / site details | Full address, description of the premises or site, use of the building, number of floors, construction type, and a site plan or floor plan showing compartmentation, escape routes, and fire assembly points |
| Responsible person | Name and contact details of the responsible person under the RRO — on a construction site this is typically the principal contractor or the employer in control of the premises |
| Assessor details | Name, qualifications, and competence of the person carrying out the fire risk assessment — the assessor must be competent by virtue of training, experience, and knowledge |
| Step 1: Identify fire hazards | Sources of ignition (hot works, electrical equipment, smoking, arson), sources of fuel (timber, insulation, packaging, flammable liquids, gas cylinders), and sources of oxygen (natural ventilation, mechanical ventilation, oxidising substances) |
| Step 2: Identify people at risk | All persons who may be affected — employees, contractors, subcontractors, visitors, members of the public, and any persons particularly at risk (lone workers, disabled persons, young workers, night shift workers) |
| Step 3: Evaluate, remove, reduce, protect | Evaluate the risk of fire occurring and the risk to people if a fire does occur. Remove or reduce fire hazards where reasonably practicable. Provide fire precautions to protect people where risks remain — detection, warning, escape routes, fire-fighting equipment, emergency lighting, signage |
| Residual risk | Assessment of the residual risk after controls are in place — rated as low, moderate, or high — with justification for the rating and identification of any areas where further action is needed |
| Action plan | Prioritised list of actions required to address any deficiencies identified in the assessment, with responsible persons, target dates, and completion dates |
| Step 4: Record, plan, inform, train | Record the significant findings. Prepare an emergency plan. Inform and instruct relevant persons. Provide fire safety training to all employees and contractors — including induction training and refresher training |
| Step 5: Review | The assessment must be kept under regular review and revised whenever there is a significant change (change of use, structural alteration, new hazard, phase transition on a construction site) or reason to suspect it is no longer valid |
| Assessor signature & date | The assessment must be signed and dated by the competent assessor to confirm the findings and recommendations |
3. Common Mistakes
Treating the fire risk assessment as a one-off document
A fire risk assessment is not a document that is completed once and then filed away. Under Article 9 of the RRO, the assessment must be kept under review and revised whenever there is reason to suspect it is no longer valid or there has been a significant change. On a construction site, the fire risk profile changes at every phase — groundworks, frame, envelope, fit-out, commissioning. A fire risk assessment that was valid during groundworks may be entirely inadequate during timber frame erection or fit-out. The assessment must be a living document, reviewed at every phase transition and whenever a significant new hazard is introduced.
No competent person carrying out the assessment
The RRO requires the fire risk assessment to be carried out by a competent person. Competence means having sufficient training, experience, knowledge, and other qualities to carry out the assessment properly. A person who has no fire safety training, no understanding of fire behaviour, and no knowledge of the relevant legislation cannot produce a suitable and sufficient fire risk assessment. On complex or high-risk premises, the responsible person should appoint a person with a recognised fire risk assessment qualification (such as a third-party certificated fire risk assessor). An incompetent assessment is worse than no assessment, because it creates a false sense of security.
Not recording all significant findings
Since the Building Safety Act 2022 s.156 removed the small employer exemption, all fire risk assessments must be recorded in writing. But even before that change, best practice required a written record. The record must include all significant findings — not just the obvious hazards, but also the less visible risks such as inadequate compartmentation, blocked escape routes, missing fire-stopping, disabled fire detection systems, and poor housekeeping. An assessment that records only the major hazards and omits the contributory factors is not suitable and sufficient.
Not sharing the findings with relevant persons
Step 4 of the five-step process requires the responsible person to inform and instruct relevant persons about the fire risks and the precautions in place. On a construction site with multiple contractors, this means communicating the fire risk assessment findings to every contractor, subcontractor, and worker on site. A fire risk assessment that sits in the site office and is never communicated to the workforce is failing in its fundamental purpose. The findings must be shared through induction, toolbox talks, and display of the emergency plan.
4. Frequently Asked Questions
Who is qualified to carry out a fire risk assessment?▾
The Regulatory Reform (Fire Safety) Order 2005 does not prescribe specific qualifications for fire risk assessors. However, the responsible person must ensure that the person carrying out the assessment is competent — meaning they have sufficient training, experience, knowledge, and other qualities to properly assess the fire risks. For straightforward, low-risk premises, a person who has completed a recognised fire risk assessment training course may be competent. For complex, high-risk, or large premises — including construction sites, high-rise residential buildings, and premises with sleeping accommodation — the assessor should hold a third-party certificated qualification from a UKAS-accredited body, such as those offered through IFE, BAFE, or similar schemes. The Fire Safety Act 2021 and the Building Safety Act 2022 have increased scrutiny of assessor competence, particularly for higher-risk buildings.
What are the penalties for failing to carry out or record a fire risk assessment?▾
Failure to comply with Article 9 of the RRO is a criminal offence. On summary conviction in the magistrates' court, the maximum penalty is an unlimited fine. On conviction on indictment in the Crown Court, the maximum penalty is an unlimited fine and/or up to two years' imprisonment. Where a failure to carry out or record a fire risk assessment contributes to a fire that causes death, the responsible person may also face prosecution for manslaughter. In addition, fire and rescue authorities have the power to issue enforcement notices, prohibition notices (which can close a premises immediately), and alteration notices. Insurance policies may also be voided if a fire risk assessment has not been carried out or is inadequate.
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Get started freeThis guide is for general informational purposes only and does not constitute legal advice. While every effort is made to ensure accuracy, regulations change and individual project circumstances vary. Construction Suite is a trading name of Xzist Digital Ltd, registered in England and Wales.