Fire Risk Assessment for Schools & MATs (UK)

A multi-academy trust doesn't run one building — it runs ten, or thirty, each with its own age, layout, occupancy and quirks. Fire risk assessment is where that complexity bites hardest, because the duty is risk-based rather than hard-dated: there's no annual certificate that simply lapses, so it's easy for a review to slip a building or two and for nobody to notice until the Fire and Rescue Authority does.

This is the school-and-trust view of the FRA: the law, who carries it, what a defensible assessment has to cover, how often to review it, and the failings that turn up again and again in education estates.

The legal basis

Fire safety in a school is governed by the Regulatory Reform (Fire Safety) Order 2005 — the "RRO" — the same law that covers offices, care homes and the common parts of residential blocks. A school is non-domestic premises, so it's squarely in scope. The RRO requires the Responsible Person to carry out and maintain a fire risk assessment, put in place appropriate fire-safety arrangements, and keep them under review.

Two later changes matter. The Building Safety Act 2022 (amending the RRO, in force 1 October 2023) removed the old exemption that let small premises skip the written record — the assessment must now be recorded in full, and the Responsible Person recorded too. The Fire Safety Act 2021 and Fire Safety (England) Regulations 2022 add duties primarily aimed at multi-occupied residential buildings; most school sites won't engage them, but a trust with residential provision (boarding, caretaker accommodation) should check.

Sitting alongside the RRO, the Department for Education's Building Bulletin 100 (BB100) is the design and management guidance specific to schools. It isn't the law, but it's the benchmark a competent assessor and an enforcing authority will reach for.

Who is the responsible person

Under the RRO the Responsible Person is the employer and/or whoever has control of the premises. For a maintained school that's usually the local authority and the governing body between them; for an academy or MAT it's the trust as employer — discharged in practice through the accounting officer (typically the CEO) and the estates or health-and-safety lead, with duties often delegated to a named person at each site.

The critical point: you can appoint a competent person to carry out the assessment — and for any non-trivial school you should — but the legal duty stays with the responsible person. If an assessment is inadequate or out of date, it's the trust and its named officers in front of the enforcing authority, not the contractor who wrote it.

In a MAT this means naming, in writing, who is responsible for fire safety at each individual academy, and who holds it at trust level. Diffuse responsibility across a portfolio is itself a finding.

What a "suitable and sufficient" assessment must cover

"Suitable and sufficient" is the statutory test, and it's a process, not a purchase. The assessment must:

• identify the fire hazards — sources of ignition, fuel and oxygen across the site;
• identify the people at risk — pupils, staff, visitors, contractors, and anyone especially at risk (very young children, pupils with disabilities or additional needs, lone workers, sleeping occupants on residential sites);
• evaluate, remove or reduce the risks, and decide what fire-safety measures are needed;
• record the significant findings and the action plan — and this is the part that matters most: an FRA with open high-risk actions is a liability, not a defence;
• set out the fire-safety arrangements — detection and alarm, escape routes and travel distances, signage, emergency lighting, extinguishers, evacuation plans (including Personal Emergency Evacuation Plans where needed);
• and be reviewed and kept current.

Most assessors work to PAS 79 for the methodology, against the school-specific benchmark of BB100.

How often to review it

Here is where schools get caught, so it's worth being exact: there is no single legal interval. The RRO requires the assessment to be reviewed regularly, kept up to date, and redone whenever there's reason to think it's no longer valid — or whenever there's been a significant change.

The workable rule most education estates adopt:

• review annually, and
• fully reassess after any material change — a new block, a classroom converted to a science lab, a mobile/temporary building added, a change in pupil numbers or in the profile of pupils with additional needs, an extension, or any incident or near-miss.

Anyone telling you "the FRA is valid for X years" has misunderstood the duty. It's valid until the building or its use changes — which, on a live school site, is often.

The school and MAT-specific angles

Breadth is the real risk. A single school is manageable; a trust of twenty sites is twenty separate assessments, each on its own review clock, each needing reassessment when that building changes. The characteristic MAT failure isn't a bad assessment — it's a good assessment on nineteen sites and a lapsed one on the twentieth, because the review date slipped and the portfolio view didn't surface it.

What's in scope vs out. Assembly halls, science labs (ignition sources, stored chemicals), kitchens, design-technology workshops, sports halls used for events, boiler rooms and plant — all firmly in scope, and all higher-hazard than a standard classroom. Sleeping risk on residential school trips is generally out of scope of the school's own premises FRA — that risk sits with the venue's Responsible Person, not the school — but on-site boarding accommodation is very much in scope, and pushes that building to the higher-frequency, higher-rigour end.

Temporary and changing fabric. Mobile classrooms, modular buildings, marquees for events, and term-by-term changes of room use are exactly the "significant change" the RRO has in mind. They're also the easiest to leave out of an assessment that was written around the permanent estate.

The findings, not the folder. Auditors and enforcing authorities don't just ask whether an FRA exists — they ask what it found and whether the actions were closed. A trust that can produce a current assessment but not a worked-through, dated action plan has a paper certificate and an open liability.

Common failings in school estates

• A lapsed review on one site in a multi-site trust — the portfolio's blind spot.
• No reassessment after a building change — a new lab, a converted space, a modular classroom added mid-year.
• Open high-risk actions left unclosed — the assessment did its job; the remediation didn't.
• No named responsible person per site — diffuse accountability that nobody owns.
• Temporary structures and changed room uses left out of scope.
• Treating the FRA as a fixed-term certificate rather than a live document.

Frequently asked questions

How often does a school fire risk assessment legally have to be reviewed?

There's no fixed legal interval. The RRO requires it to be reviewed regularly, kept up to date, and redone after any significant change. In practice trusts review annually and reassess after any material change to a building or its use. Treating it as "valid for X years" misreads the duty.

Who is the responsible person in a multi-academy trust?

The trust, as employer, is the Responsible Person — discharged in practice through the accounting officer (usually the CEO) and the estates/health-and-safety lead, with a named person often holding it at each academy. The assessment work can be delegated to a competent assessor; the legal duty cannot be delegated away.

Are residential school trips covered by the school's fire risk assessment?

Generally no — the sleeping-accommodation fire risk at a trip venue is the responsibility of that venue's own Responsible Person, not the school's premises FRA. But on-site boarding accommodation is in scope and carries a higher-rigour, higher-frequency duty because of the sleeping risk.

What happens if a trust's FRA is out of date?

Enforcement is by the local Fire and Rescue Authority, which can serve alterations, enforcement and prohibition notices and prosecute. Serious breaches carry unlimited fines and up to two years' imprisonment, and the named responsible person — at trust level — is the one in the dock.

Where this fits

Fire is one of a dozen statutory regimes an estates team carries at once. The FRA sits alongside electrical (EICR), gas, legionella, asbestos, lifts, emergency lighting and fire-alarm servicing — each on its own clock, several of them, like fire, risk-based rather than hard-dated. Our statutory compliance calendar for estates teams maps the full set: what each is, who's liable, and how often it's due.

Across a trust the failure mode is never "we didn't know fire mattered" — it's "the review date slipped on one site and nobody noticed." That portfolio-wide slippage is precisely what software should prevent. Proprietas tracks the FRA review date per building, drives the status from valid to due-soon to overdue, and chases it at 90/60/30/7 days across every academy in the trust — with the assessment's findings and actions tracked alongside, and remedials raised straight into work orders. You can try it on one of your own assessments before committing to anything.

This is a plain-English overview for school and trust estates teams, not legal advice — your specific duties depend on your buildings and how they're used.