Freeholders of residential blocks in London face an increasingly complex set of fire safety obligations. The Building Safety Act 2022, Fire Safety Act 2021 and associated regulations have significantly expanded the duties placed on those who own and manage residential buildings. Understanding these obligations is essential to managing risk, maintaining compliance and protecting residents.
The regulatory framework for fire safety in residential buildings has undergone substantial reform since the Grenfell Tower tragedy in 2017. The Fire Safety Act 2021 clarified that the Regulatory Reform (Fire Safety) Order 2005 applies to the structure, external walls and flat entrance doors of residential buildings containing two or more sets of domestic premises. The Building Safety Act 2022 introduced a new regulatory regime for higher-risk buildings, including mandatory registration, accountable person duties and building safety cases.
For freeholders of residential blocks in London, these changes mean new obligations that require active management, professional advice and ongoing compliance. The days of treating fire safety as an annual tick-box exercise are over. The regulatory expectation is now that fire safety is managed proactively, with clear evidence of decision-making, competent assessments and a defensible approach to risk management.
The Building Safety Act 2022 introduces specific duties for higher-risk buildings (18 metres or seven storeys and above, with at least two residential units). The key requirements include registration with the Building Safety Regulator, identification and appointment of the Accountable Person and Principal Accountable Person, preparation and maintenance of a building safety case, establishment of a resident engagement strategy, management of building safety information (the golden thread), and notification of safety occurrences to the Regulator.
Even for buildings below the higher-risk threshold, the Act has wider implications. The principles of competence, accountability, clear documentation and resident engagement are expected across all residential buildings, even if the specific registration and safety case requirements do not apply.
The Fire Safety Act 2021 and accompanying Regulations apply to all residential buildings with two or more sets of domestic premises. Key requirements include an updated fire risk assessment that covers the structure, external walls and flat entrance doors, regular inspection of fire doors in common areas (quarterly) and flat entrance doors in buildings over 11 metres (annually), provision of fire safety information to residents, information sharing with the fire and rescue service, and clear wayfinding signage and premises information boxes in buildings over 11 metres.
Where a building has any form of external cladding, render system, external wall insulation or non-traditional external wall construction, a Fire Risk Appraisal of External Walls (FRAEW) under PAS 9980:2022 should be considered. This proportionate, risk-based assessment determines whether the external wall system presents a fire risk and, if so, the appropriate remediation scope. A FRAEW is also essential for informing EWS1 outcomes and supporting funding applications.
Fire compartmentation is the principle that fire and smoke should be contained within defined compartments to prevent spread and allow safe evacuation. Common defects include breaches in compartment walls and floors (often caused by subsequent service installations), failed or missing fire stopping around pipes and cables, inadequate fire barriers in roof voids and deficient compartmentation between flats and common areas. Compartmentation surveys identify these defects and inform the remediation programme.
Fire doors are a critical element of the passive fire protection strategy in residential blocks. They protect escape routes, contain fire and smoke within compartments and provide residents with time to evacuate safely. Under the Fire Safety (England) Regulations 2022, fire doors in common areas must be inspected quarterly, and flat entrance doors in buildings over 11 metres must be inspected annually. Inspections should assess the door leaf, frame, ironmongery, intumescent strips, smoke seals and self-closing device.
Buildings that meet the higher-risk threshold (18 metres or seven storeys, with two or more residential units) must be registered with the Building Safety Regulator. Registration requires identification of the building, its height, the number of residential units and the details of the Accountable Person. Failure to register is a criminal offence. The registration deadline has passed, and any unregistered buildings must be registered immediately.
The most effective approach is to develop a structured compliance roadmap that prioritises actions based on risk and regulatory urgency. This should begin with a thorough review of the current fire risk assessment, an assessment of the external wall system (where relevant), a compartmentation survey, fire door inspections and a gap analysis against the Building Safety Act requirements for higher-risk buildings.
Each of these assessments will generate findings and recommendations that need to be prioritised, budgeted and programmed. A clear, documented compliance roadmap demonstrates to the Regulator, insurers and residents that the freeholder is taking a proactive and structured approach to fire safety.
The regulatory framework places significant emphasis on competence. Fire risk assessments must be carried out by competent assessors. FRAEW assessments must be carried out by professionals with the relevant qualifications and experience under PAS 9980. Fire door inspections must be carried out by competent persons. Freeholders must satisfy themselves that the professionals they appoint are genuinely competent for the specific task, not simply the cheapest available option.
The golden thread concept requires that key building safety information is created, maintained and accessible throughout the life of the building. This includes design and construction information, fire safety assessments, remediation records, maintenance logs and compliance documentation. For many existing buildings, assembling this information retrospectively is a significant undertaking. Starting now and building the information set systematically is the practical approach.
The Building Safety Act requires freeholders of higher-risk buildings to establish a resident engagement strategy. Even for buildings below the threshold, good practice dictates that residents should be informed about fire safety arrangements, evacuation strategies and any ongoing compliance work. Transparent communication builds trust and helps ensure that residents understand their own responsibilities, such as not propping open fire doors or storing combustible items in common areas.
A higher-risk building is defined as a residential building that is at least 18 metres in height or has at least seven storeys, and contains at least two residential units. These buildings are subject to the most stringent requirements under the Act, including registration with the Building Safety Regulator, appointment of an Accountable Person and Principal Accountable Person, preparation and maintenance of a building safety case, and establishment of a mandatory resident engagement strategy.
A Fire Risk Appraisal of External Walls (FRAEW) under PAS 9980:2022 is recommended wherever there are concerns about the external wall system. This includes buildings with any form of cladding, render system, external wall insulation or non-traditional external wall construction. A FRAEW is also needed to support EWS1 assessments, inform remediation decisions and support applications to government funding schemes such as the Cladding Safety Scheme or Building Safety Fund.
Under the Fire Safety (England) Regulations 2022, fire doors in common parts of all residential buildings with two or more sets of domestic premises must be inspected at least every three months (quarterly). Flat entrance doors in buildings over 11 metres in height must be inspected at least annually. These inspections should be carried out by a competent person and should assess the door leaf, frame, ironmongery, intumescent strips, smoke seals and self-closing device. Findings and remedial actions should be recorded.
A building safety case is a comprehensive set of documents that demonstrates how fire and structural safety risks in a higher-risk building are being identified, assessed and managed on an ongoing basis. It must include a safety case report that summarises the risk management approach, supported by all relevant assessments, reports, strategies and management documentation. The Principal Accountable Person is responsible for preparing, maintaining and, when requested, submitting the building safety case to the Building Safety Regulator.
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