BS 9792: The New Fire Safety Code of Practice -- What Responsible Persons and Assessors Need to Know

The publication of BS 9792 in late 2024 marks one of the most significant shifts in UK fire risk assessment guidance in over a decade. Replacing the withdrawn PAS 79-2, this new British Standard raises the bar for how fire risk assessments are conducted, documented, and scrutinised across all residential building types.

If you are a responsible person, property manager, landlord, or fire risk assessor, understanding what BS 9792 requires -- and how it differs from previous guidance -- is not optional. Fire and rescue services are already using the new standard as a benchmark when inspecting buildings and challenging the adequacy of existing fire risk assessments.

Why Was a New Standard Needed?

The Grenfell Tower Inquiry Phase One report, published in October 2019, delivered severe criticism of the fire risk assessment guidance that existed at the time. The inquiry panel found that PAS 79-2:

- Failed to adequately address the needs of occupants, particularly vulnerable residents
- Wrongly stated that there was no practical way of identifying and providing for vulnerable persons
- Relied too heavily on limited visual inspections of buildings
- Lacked thoroughness in the fire risk assessment process overall

A significant number of those who lost their lives in the Grenfell Tower fire were individuals considered to be vulnerable. The message from the inquiry was clear: the industry was not dealing with fire risk assessments and fire safety to the standard that was needed.

PAS 79-2 was formally withdrawn by the BSI in early 2021, and work began on its replacement. Although the new standard was originally expected in 2024, the introduction of Section 156 of the Building Safety Act in October 2023 required the BSI to go back and rethink its approach, ensuring the new code properly reflected the significantly expanded legislative landscape.

Section 156 of the Building Safety Act: The Catalyst for Change

A common misconception is that the Building Safety Act only applies to residential buildings. In reality, Section 156 amended the Regulatory Reform (Fire Safety) Order 2005 (the Fire Safety Order), and its changes affect all types of buildings and workplaces covered by that order -- residential, commercial, retail, industrial, and beyond.

Section 156 came into force on 1 October 2023, and its impact has been profound. The key changes include:

All fire-related risks, not just "significant" risks. Prior to October 2023, a fire risk assessment only had to identify the significant risks. Section 156 removed that qualifier. Fire risk assessments must now consider all fire-related risks -- a much more comprehensive and robust requirement.

Identification of all responsible persons. Responsible persons must now take reasonable and reasonably practicable steps to ascertain the existence of other responsible persons who share duties in respect of the same premises. This includes identifying any accountable persons under the Building Safety Act. Critically, you must also identify a UK address for each responsible person -- an obligation that is causing practical challenges across the sector.

Information sharing between responsible persons. When a property changes hands -- for example, when a new managing agent takes over from a previous one -- the outgoing responsible person must provide the incoming party with all fire safety information: previous fire risk assessments, fire strategies, as-built fire plans, maintenance and testing records, and all related documentation.

Resident communication. Responsible persons must provide residents with relevant fire safety information in a format that is easily understood. For higher-risk buildings (HRBs) -- those 18 metres or seven storeys or more, containing two or more residential units in England -- a summary of the fire risk assessment findings must also be provided to residents in accessible language.

What Does BS 9792 Cover?

The new standard applies to:

- Houses in multiple occupation (HMOs)
- Blocks of flats -- both purpose-built and converted
- Specialised housing such as supported or sheltered accommodation
- Purpose-built student accommodation and other qualifying student housing
- Common areas of mixed-use buildings that provide access to residential premises

It does not apply to private single-household dwellings, short-term lets, care homes, or non-domestic premises.

The Five Pillars of BS 9792

To help make sense of the new requirements, it is useful to think of BS 9792 as resting on five pillars. If you address each of these, your fire risk assessments should align with the standard's expectations.

#### 1. Justification

Every fire safety measure in place must be accompanied by sufficient commentary and assessment explaining its acceptance or non-acceptance. Simply noting that a fire alarm system exists is no longer adequate. The assessment must explain:

- What type of system is installed (alarm, detection, or both)
- What category it falls under
- What it is designed to do
- Where it is located
- What evidence supports its adequacy

In short: the who, what, why, and where of every fire safety measure must be documented and evidenced.

#### 2. Coverage

The assessment must provide a proper check of all areas affected, including those that may be under the control of others. You cannot simply assess the areas you directly manage while ignoring what is happening on the other side of a shared wall or on a different floor.

#### 3. Technical Consideration

All fire safety systems -- both active (fire alarms, sprinklers, smoke ventilation) and passive (compartmentation, fire doors, fire stopping) -- must be examined. The approach echoes Dame Judith Hackitt's recommendation that buildings should be considered as a system: a collection of connected protective controls, measures, and layers.

#### 4. Consideration of All Persons at Risk

The assessment must consider all people who may be affected by fire risks, taking into account the number of occupants, the nature of the occupancy, and the specific needs of vulnerable residents.

#### 5. Competence of the Assessor

The person undertaking the fire risk assessment must have the skills, knowledge, experience, and behaviours required to deliver the assessment to the standard expected. This is now supported by a separate British Standard -- BS 8674 -- which provides a formal competence framework for fire risk assessors.

What This Means in Practice

Fire and rescue services across England and Wales are already referencing BS 9792 when reviewing fire risk assessments -- even those completed only months before the standard was published. Assessments that do not meet the new expectations are being challenged, and enforcement action to require improvements is following.

The days of tick-box-only assessments are over. A tick box is acceptable as a recording tool, but only if it is accompanied by commentary and justification explaining why that box has been ticked, what evidence supports the conclusion, and how the specific fire safety measure meets the required standard.

For responsible persons and property managers, the practical steps are clear:

1. Confirm your assessor is working to BS 9792. Ask them directly whether their methodology aligns with the new code of practice.
2. Review the coverage level of your assessments. Is a Type 1 (common areas, non-intrusive) assessment truly sufficient for your building, or does its history, construction, or risk profile demand a more detailed approach?
3. Verify your assessor's competence. Look for membership of recognised third-party schemes and ask about qualifications, experience, and the specific types of buildings they are experienced in assessing.
4. Ensure your documentation is in order. The "golden thread" of building safety information -- fire strategies, as-built plans, maintenance records, test certificates -- must be available to support any fire risk assessment.
5. Act promptly on findings. Where a fire risk assessment identifies remedial actions, prioritise and complete them systematically. A management action plan gathering dust is a liability, not a defence.

The Question You Should Be Asking Yourself

With the new legislation and the new code of practice now in force, the test for any responsible person is straightforward: would you be confident standing before a judge -- or, hopefully never, a coroner -- and stating that your fire risk assessment is suitable and sufficient?

If the answer is anything other than an unequivocal yes, now is the time to review your approach. The regulatory landscape has shifted. The expectations are higher. And the consequences of falling short remain as serious as they have always been.