How the standard is judged.
Neither the Order nor case law prescribes a template. Enforcement officers, and ultimately courts, test an assessment against the relevant government guidance document for the building type (the sector guides for offices and shops, sleeping accommodation, residential care, educational premises and so on) and against recognised methodology — in practice PAS 79-1 for non-domestic premises and PAS 79-2 for housing. The questions asked are consistent:
- Were all significant ignition, fuel and oxygen hazards identified — including arson?
- Were persons at risk identified by category, including those needing evacuation assistance?
- Was the assessment specific to this building — construction, compartmentation, travel distances, evacuation strategy — rather than generic?
- Were existing measures benchmarked against the applicable guidance, with shortfalls converted into a prioritised, dated action plan?
- Was the assessor competent for this category of premises (Article 9A)?
- Is the assessment current — reviewed since the last material change?
The failures that void an assessment.
| Failure mode | Example | Consequence |
|---|---|---|
| Generic template | Identical wording deployed across unrelated premises; floor plans and travel distances absent | Not specific to the premises — fails the suitability limb |
| Scope gap | Block of flats assessed without external walls or flat entrance doors post-2021 | Unlawfully narrow since the Fire Safety Act 2021 |
| Occupancy blindness | Care home assessed without PEEPs or night-staffing analysis | Persons most at risk not addressed |
| Stale document | Assessment predating a mezzanine installation or change of use | No longer valid — review duty breached |
| Findings without action | Deficiencies listed, no owner, priority or deadline assigned | Assessment exists but precautions duty (Article 8) breached |
| Incompetent assessor | Complex sleeping-risk premises assessed by an untrained duty-holder | Article 9A breach; assessment findings unreliable |
"A suitable and sufficient risk assessment... should identify the risks arising in respect of the particular premises, having regard to their particular use and occupancy."Approach applied in fire safety prosecutions under the Order
Proportionality cuts both ways
A small lock-up shop does not need a fifty-page report; a converted HMO with sleeping risk cannot be discharged with two pages. The standard scales with sleeping risk, occupant vulnerability, building height and complexity, and the consequences of fire spread. This is also how assessment pricing scales.
Evidence of sufficiency
A defensible assessment records its own methodology (PAS 79 reference), the guidance benchmark used, the areas inspected and any areas not accessed, photographic evidence of significant findings, and the assessor's identity and competence credentials — all now required or expected following Section 156.