Fire Risk Assessments for Schools: Understanding Changes to the Fire Safety Act

Fire safety is a fundamental responsibility for every school leader. But it’s also an area where legislation is tightening, enforcement is increasing, and the consequences of failure can be severe. Recent changes to fire safety law have raised the bar for what “adequate” fire risk assessment means—and many schools are unprepared.

This newsletter explains what’s changed, why it matters, and what school leaders need to do right now to stay compliant and protect their pupils and staff.

What’s Changed in Fire Safety Legislation?

The Fire Safety Act 2021 and subsequent regulatory updates have significantly strengthened fire safety requirements for schools. The most important changes include:

1. Stricter Definition of Fire Risk Assessments

Fire risk assessments are no longer optional or periodic. They must be:

Comprehensive — covering all aspects of the building, systems, and procedures
Current — updated whenever the premises change significantly
Documented — with clear evidence of findings and corrective actions
Actioned — findings must be implemented, not just recorded

Schools can no longer treat fire risk assessments as a compliance checkbox. They’re a living document that reflects your actual fire safety position.

2. Designated Responsible Person Requirements

Every school must now clearly identify:

Who is responsible for fire safety (typically a member of senior leadership)
What their authority is — ensuring they have power to make and implement decisions
How they’re trained — demonstrating competence in fire safety law and procedures
How they’re supported — ensuring they’re not isolated in their responsibility

This moves fire safety from being “someone’s job” to being a clear governance responsibility with named accountability.

3. Enhanced Risk Assessment Scope

Recent guidance expands what must be assessed:

Building fabric and structure — fire ratings, compartmentation, structural integrity
Fire detection and alarm systems — functionality, testing, maintenance records
Emergency evacuation — routes, signage, procedures, including vulnerable occupants (PEEPs)
Fire suppression equipment — extinguishers, sprinklers, hose reels, maintenance
Staffing and competence — training levels, emergency procedure knowledge
Occupant vulnerability — specific needs of children, staff with disabilities, visitors
Maintenance and management — audit trails showing ongoing compliance

This is far broader than traditional fire safety assessments and requires expertise beyond standard building maintenance knowledge.

4. Increased Enforcement and Penalties

Fire service enforcement has become more active and penalties more severe:

Fire safety breaches can result in prosecution of responsible persons
Corporate liability — the school itself can face criminal prosecution
Prison sentences — for gross negligence resulting in death (Corporate Manslaughter Act)
Regulatory attention — fire services now conduct regular proactive inspections, not just reactive investigations

Schools are no longer given the benefit of the doubt. Enforcement bodies assume responsibility unless the school can prove otherwise.

Why Fire Risk Assessments Matter More Than Ever

For school leaders, fire safety has moved from an operational task to a governance responsibility. Here’s why:

It’s a Legal Duty

The Regulatory Reform (Fire Safety) Order 2005 and the Fire Safety Act 2021 impose a legal duty on school leaders to:

Conduct competent fire risk assessments
Identify and manage fire hazards
Ensure adequate fire precautions are in place
Maintain records and evidence of compliance

Failure to do this is a criminal offense—not just for the school, but potentially for individual leaders.

It’s an Enforcement Priority

Fire services increasingly treat school fire safety as a high-priority enforcement area. Why?

Schools have vulnerable occupants (children)
Schools have complex buildings with shared spaces
Fire safety is often underfunded compared to other priorities
Historic undercompliance has created regulatory focus

When fire services inspect schools, they’re looking for evidence of systematic fire safety management. If they don’t find it, enforcement action follows quickly.

It Demonstrates Leadership Accountability

Fire risk assessments create documented evidence that:

Leadership understands the fire safety risks
Appropriate precautions are in place
Responsible persons are competent and empowered
Corrective actions are being taken
The school is actively managing fire safety, not hoping nothing bad happens

This evidence is critical if an incident occurs. It demonstrates that the school took reasonable precautions and acted responsibly.

It Protects Pupils and Staff

Beyond compliance, comprehensive fire risk assessments actually reduce risk. They:

Identify hazards that might otherwise go unnoticed
Ensure emergency procedures are robust and tested
Verify that vulnerable occupants have specific plans
Create accountability for maintaining fire safety systems

A thorough assessment improves actual safety—not just paperwork.

What Does a Compliant Fire Risk Assessment Look Like?

Under current legislation, a compliant assessment includes:

1. Hazard Identification

All potential sources of ignition (electrical equipment, heating systems, etc.)
All potential fuel sources (materials, furnishings, storage)
All potential ignition pathways and factors that could accelerate fire spread
Building-specific hazards (old wiring, complex layouts, high-risk areas)

2. Risk Evaluation

Likelihood of a fire occurring
Potential consequences if it did
Effectiveness of existing controls in reducing likelihood and consequence
Whether residual risks are acceptable

3. Control Measures

What fire precautions are currently in place
Whether they’re adequate for the identified risks
What additional measures are needed
Priority and timeline for implementation

4. Vulnerable Occupants

Specific fire safety needs of children (age, mobility, cognitive ability, special needs)
Staff training and competence levels
Procedures for assisting vulnerable occupants during evacuation
Documentation of Personal Emergency Evacuation Plans (PEEPs)

5. Emergency Procedures and Testing

Documented emergency evacuation procedures
Regular practice evacuations (minimum annually, preferably termly)
Testing of fire detection and alarm systems
Maintenance records for all fire safety systems
Staff training records

6. Management and Monitoring

Named responsible person with defined authority
Regular review and update procedures
Documented decision-making about fire safety
Records of maintenance, testing, and corrective actions
Training schedules and competence records

The Specific Requirements for School Leaders

If you’re a headteacher, CEO, or trustee, fire safety is now a direct governance responsibility. Specifically:

You Must:

Appoint a named, competent person responsible for fire safety
Ensure a current, comprehensive fire risk assessment exists
Understand the assessment findings and what they mean
Approve corrective actions and verify they’re being implemented
Ensure appropriate training and competence across the school
Maintain documentation and audit trails
Review fire safety performance regularly (at least annually)
Report fire safety status to governors/trustees

You Cannot:

Delegate fire safety responsibility to someone without authority
Conduct assessments with inadequate expertise
Ignore findings from assessments or fire service inspections
Assume fire safety is “fine” without current evidence
Allow staff to be untrained in emergency procedures
Postpone implementing corrective actions

Failure to do these things puts you—personally—at risk of prosecution.

What Schools Should Do Now

If your school hasn’t reviewed fire safety in light of recent legislative changes, here’s what to do:

1. Commission a Current Fire Risk Assessment

Not a cursory review—a comprehensive assessment conducted by someone genuinely competent in school fire safety law and building systems. This assessment should:

Evaluate your building against current standards
Identify specific gaps and required corrective actions
Provide a report suitable for governance reporting
Include recommendations prioritized by risk level

2. Identify Your Responsible Person

Appoint someone with:

Authority to make and implement decisions
Appropriate training and competence
Time and resources allocated to the role
Direct line to senior leadership
Accountability to governors

3. Implement Corrective Actions

Prioritize according to risk level and work systematically through identified gaps. Don’t cherry-pick easy fixes while ignoring complex issues.

4. Document Everything

Maintain records of:

Assessment findings and recommendations
Decisions made and why
Actions taken and when
Testing and maintenance activities
Staff training and competence
Regular review and updates

5. Review Regularly

At minimum annually, but more frequently if:

The building changes
Procedures change
Staffing changes significantly
Incidents occur
Inspection findings emerge

The Cost of Non-Compliance

Schools that don’t take fire safety seriously face serious consequences:

Prosecution of responsible persons under fire safety law
Corporate prosecution of the school itself
Reputational damage affecting pupil recruitment and staff retention
Insurance complications if a fire occurs and inadequate precautions are found
Personal liability for school leaders
Criminal penalties including fines and potential imprisonment in serious cases

The cost of compliance is significant. The cost of non-compliance is far greater.

Taking Action: Why Expert Support Matters

Fire risk assessments require genuine expertise. Not just in health and safety generics, but specifically in:

Fire safety law and recent legislative changes
Building systems and fire ratings
School-specific risks and vulnerabilities
Governance and leadership accountability
Documentation and evidence systems

Schools trying to manage this without expert support often end up with assessments that look good on paper but don’t actually reflect their risk position or satisfy enforcement scrutiny.

This is exactly where specialist fire safety support makes a difference. A professional assessment:

Identifies risks that internal reviews would miss
Provides findings in a format suitable for governance reporting
Creates defensible documentation for enforcement bodies
Prioritizes actions based on genuine risk assessment
Gives leadership confidence that fire safety is genuinely managed

What’s Next?

Fire safety is no longer optional or peripheral to school management. Recent legislative changes have made it a core governance responsibility with serious personal and corporate consequences.

If your school hasn’t conducted a current, comprehensive fire risk assessment in light of recent legislative changes, now is the time. Don’t wait for a fire service inspection or an incident to prompt action.

The School Safety People provide specialist fire risk assessment services designed specifically for schools. We assess your building, systems, and procedures against current legislation, identify specific gaps, and provide prioritized recommendations. Our assessments are designed to give school leaders the evidence and assurance they need to demonstrate compliance and protect their pupils and staff.

Learn more about our fire risk assessment services

If you’d like to discuss your school’s fire safety position or need support with a current assessment, contact us today.