External Wall Fire Risk Assessments: What Building Professionals Need to Know About FRAEWs

The inclusion of external walls, cladding systems, and attachments within the scope of the Regulatory Reform (Fire Safety) Order 2005 — brought about by the Fire Safety Act 2021 — represents one of the most significant practical challenges facing the fire safety sector. For fire risk assessors, responsible persons, and managing agents, understanding the implications, limitations, and recommended approach is essential.

What the Legislation Actually Requires

The Fire Safety Act 2021 clarifies that external walls and their attachments (including cladding and balconies) fall within the scope of the Fire Safety Order. In practice, this means that a fire risk assessment for a block of flats should, in principle, consider the fire risk posed by external walls.

However, this does not mean that every fire risk assessor must become an expert in external wall construction and cladding systems. The fire safety sector has been clear that the typical fire risk assessor is not competent to assess the fire performance of external walls — and this was communicated to government during the legislative process.

Why Most Fire Risk Assessors Should Exclude External Walls

The industry's prevailing guidance to fire risk assessors is straightforward: exclude the external wall from the fire risk assessment and recommend that a specialist assessment be commissioned.

This is not an abdication of responsibility. It reflects three practical realities:

1. Competence

Assessing the fire performance of a cladding system requires specialist knowledge of building envelope construction, material properties, fire testing regimes, and system interaction. This is a different discipline from general fire risk assessment. A fire risk assessor who lacks this specialist knowledge and attempts to assess external walls risks providing inaccurate or misleading advice.

2. Willingness

Even among those with relevant expertise, many practitioners and their firms have chosen not to offer external wall assessment services due to the risk profile and liability exposure.

3. Insurance

Professional indemnity insurers have been cautious about covering external wall assessments. The number of practitioners who are competent, willing, and insured to conduct these assessments is very small. This creates a significant capacity constraint that will take years — not months — to resolve.

The Exception: Traditional Masonry Construction

The guidance has been refined to avoid creating unnecessary burden for buildings that clearly do not have hazardous cladding. Where the fire risk assessor can confidently identify that a building has traditional masonry external walls (i.e. solid brick or block construction without modern cladding or rain-screen systems), the approach is pragmatic:

- Do not declare that the walls comply with building regulations (either current or those in force when the building was constructed)
- Do make a professional, risk-based judgement that the traditional masonry wall does not constitute an undue risk
- Do move on to focus the fire risk assessment on other matters

This prevents low-risk buildings from consuming specialist resources that are needed for genuinely problematic cladded buildings.

For anything beyond straightforward masonry — any building with modern cladding systems, composite panels, render systems, or rain-screen facades — the fire risk assessor should recommend a specialist assessment.

Fire Risk Appraisals of External Walls (FRAEWs)

The specialist assessment that sits alongside the fire risk assessment is known as a Fire Risk Appraisal of External Walls, or FRAEW. The national code of practice for FRAEWs is PAS 9980, published by BSI and available as a free download (funded by government to ensure accessibility).

PAS 9980 was developed by a collaboration of leading fire safety practices and provides a structured, risk-based methodology for assessing external wall systems. It is not a legally binding standard, but it represents the national consensus on how these assessments should be conducted.

A FRAEW typically involves:

- Desktop review of the building's construction details, original building control approvals, and any available fire test data for the cladding system
- Visual inspection of the external walls from ground level and, where necessary, closer inspection of specific areas
- Assessment of the risk posed by the cladding system, considering the building's height, the nature of the cladding materials, the presence or absence of cavity barriers, and the overall system configuration
- Recommendations for remediation, interim measures, or monitoring as appropriate

Using the Risk Prioritisation Tool

The government recognised early on that the capacity to conduct FRAEWs would not match the demand. To manage this, the Home Office produced a risk prioritisation tool that allows responsible persons to triage their building portfolios.

The tool helps you determine:

- Which buildings need an immediate specialist FRAEW
- Which buildings can wait, and for how long
- Which buildings are low priority and can be addressed at the next routine fire risk assessment review

Why this matters legally: The Fire Safety Act includes a provision on "risk-based guidance." If a responsible person can demonstrate that they are following the risk prioritisation tool and managing their building portfolio accordingly, this will tend to demonstrate compliance in any legal proceedings. Conversely, a responsible person who ignores the prioritisation tool and takes no steps toward external wall assessment could face criminal prosecution.

The practical effect is a structured, defensible approach to managing the queue. It acknowledges that not every building can be assessed immediately while requiring responsible persons to take active steps rather than simply ignoring the obligation.

What to Include in the Fire Risk Assessment

Even when the fire risk assessor excludes the external wall from the scope of the fire risk assessment (as recommended), the assessment should still:

1. State explicitly that the external wall has been excluded from the scope of the assessment
2. Explain why — typically because the assessor does not hold the specialist competence to assess cladding fire performance
3. Recommend that the responsible person commissions a specialist FRAEW
4. Reference the risk prioritisation tool and suggest the responsible person uses it to determine the urgency
5. Note any visible concerns — if there are obvious external features that raise concern (e.g. visible composite panels, damaged or deteriorating cladding, missing ventilation barriers), these should be flagged even if the assessor cannot make a definitive assessment of fire performance

This approach is transparent, defensible, and protects both the fire risk assessor and the responsible person.

For Responsible Persons: A Step-by-Step Approach

If you are responsible for one or more blocks of flats, here is a practical sequence for addressing external wall compliance:

Step 1: Identify Your Buildings

Compile a list of all blocks in your portfolio. For each, record:

- Height (metres and storeys)
- Construction type (traditional masonry, modern cladding, mixed)
- Year of construction
- Whether there is any known cladding or external wall system

Step 2: Apply the Risk Prioritisation Tool

Use the Home Office risk prioritisation tool to categorise each building by urgency. This will produce a priority ranking that can guide your commissioning schedule.

Step 3: Commission FRAEWs for High-Priority Buildings

For buildings flagged as high priority, commission a specialist FRAEW under PAS 9980 as soon as practicable. Be aware that specialist availability is limited and waiting times may be significant — starting the process early is important.

Step 4: Implement Interim Measures Where Needed

For buildings awaiting assessment, consider whether interim safety measures are needed, such as:

- Enhanced fire detection in common areas
- Waking watch or fire alarm systems in lieu of waking watch
- Updated resident communications about the evacuation strategy
- Liaison with the local fire and rescue service

Step 5: Document Everything

Maintain a clear record of:

- The prioritisation exercise and its outcome
- All commissioning and correspondence related to FRAEWs
- Interim measures implemented and their rationale
- Updates to the fire risk assessment referencing the external wall position

Step 6: Record External Wall Design and Materials

For high-rise buildings (18 metres or 7+ storeys), the Fire Safety (England) Regulations 2022 require a record of the design and materials of external walls, including mitigation measures for identified risks. This must be shared electronically with the fire and rescue service.

Step 7: Monitor and Update

The external wall position is not static. As FRAEWs are completed, remediation works progress, and interim measures are reviewed, update your records and fire risk assessments accordingly.

Looking Ahead: The Capacity Challenge

The sector-wide shortage of competent, willing, and insured external wall assessors means that full compliance will take years to achieve across the building stock. This is understood by both the government and the enforcing authorities.

What they will not accept is inaction. The combination of the risk prioritisation tool, the risk-based guidance provisions of the Fire Safety Act, and the regulatory requirements for high-rise buildings creates a clear framework for responsible persons to follow. Those who engage with the framework — even if their building is still in the queue for assessment — are in a far stronger position than those who do nothing.

The fire safety sector is actively working to expand capacity through training, accreditation, and professional development programmes. As more practitioners become qualified to conduct FRAEWs, waiting times should reduce. In the meantime, the risk-based, prioritised approach is the legally supported and professionally defensible path forward.