Since October 2023 a Responsible Person may only appoint a competent person to help with their fire risk assessment. This guide sets out how a practice evidences competence for every assessor and every building, and how it checks reports before they go out.
Section 156 of the Building Safety Act 2022 inserted Article 9A into the Regulatory Reform (Fire Safety) Order 2005, in force from 1 October 2023. A Responsible Person must not appoint a person to assist with making or reviewing the fire risk assessment unless that person is competent, and competent means having sufficient training and experience or knowledge and other qualities to assist properly. The Order does not name a qualification. The Responsible Person has to be satisfied, and a prudent one will ask the practice how.
For the practice, the consequence is that competence is decided every time a visit is scheduled. An assessor who is entirely competent for a suite of offices is not necessarily competent for a care home, a building with a complex fire strategy or a block of flats over 18 metres. A practice that sends whoever is free is making a competence decision by accident, and if the report is ever challenged the first question will be why that person was chosen for that building.
Quality assurance is the other half. Competence gets the right person to the building; QA is how the practice stands behind what they wrote. Without it, the only check on a report is the client's reading of it, and the first thing a fire officer notices across a portfolio is two assessors describing the same kind of building two different ways.
Hold a competence record for every assessor as structured data rather than a certificate in a personnel file: qualifications, professional registrations and any third-party certification, experience by class of building, CPD, and a sign-off per building class by a named senior person. The scheduler reads that record. A building class the assessor is not signed off for cannot be assigned to them without an override, and the override is recorded with its reason.
Run QA as a stage in the workflow with a named reviewer, a checklist and a sampling rule the practice has written down. A report cannot move to issue until the stage is complete. Alongside the per-report check, calibrate assessors against each other periodically, by having more than one person band the same findings and comparing the results, so that a high priority means the same thing whoever wrote it.
The payoff is an evidence pack the practice can produce in minutes when asked: who assessed the building, what their competence record showed on that date, who reviewed the report, what was checked and what was changed. A Responsible Person asking how the assessor was chosen gets an answer rather than an assurance.
Follow these steps to turn competence from an assumption into a record, and QA from a favour into a stage.
List the classes of building the practice assesses: offices and retail, sleeping accommodation, care and healthcare, residential blocks by height and construction, industrial, heritage, and any specialist class. List the assessors. For each cell, record whether the assessor is signed off, supervised only, or not yet, and who made that decision and when.
For each building class, define what the practice expects before signing someone off: the qualification or registration, the number of supervised assessments, the building types observed, and the senior review of their early reports. Recognised registers and certification schemes are part of the picture, and the competency criteria published by the Fire Risk Assessment Competency Council are widely used as the benchmark.
When a visit is assigned, the system checks the assessor's sign-off for that building class. If they are not signed off, assignment needs an override from a named senior person with a reason recorded on the case, for instance that the assessor will be accompanied. The record of who was assigned, and why, then exists for every assessment without anyone writing it up.
Decide the sampling rule and record it. Every report from an assessor in their first year. Every report on sleeping accommodation, care premises and higher-risk buildings. A defined proportion of everything else, weighted towards unusual buildings. The rule is the practice's professional judgement; what matters is that it is written down, applied, and can be explained.
The reviewer confirms that the scope on the report matches the instruction, that every significant finding is supported by a photograph or an observation, that priorities follow the practice's banding, that actions are specific enough for a building manager to act on, that the full assessment is recorded as the Order now requires, and that the assessor is named. Each item is answered, and the review is recorded with the reviewer's name.
Periodically, take a sample of findings and have several assessors band them independently, then compare. Where they diverge, agree the practice's position and record it. Over time this builds a reference set of worked examples that new assessors learn from and experienced ones are measured against.
Registration renewals, certification expiries and CPD requirements are dates on the assessor's record, and they raise tasks before they fall due. A lapsed registration changes the sign-off status automatically, so the scheduler stops assigning that class until it is renewed.
Competence decisions need an owner. One senior person, or a small panel for a larger practice, signs off each cell of the matrix and is recorded as having done so. A decision with no name on it is not a decision the practice can defend.
Trainees learn by assessing real buildings. The report should show that the assessment was carried out under supervision and co-signed by a competent person, so nobody has to discover it later.
Sleeping accommodation, care premises, hospitals and higher-risk residential buildings are where a missed finding costs most. Those reports are reviewed every time, whoever wrote them.
The useful record is why this assessor went to this building. Where that needed an override, the reason is the evidence; where it did not, the matrix is.
Test it. Pick a report issued last year and see how long it takes to produce who assessed, their record on that date, who reviewed and what was checked. If the answer is a day, the system is not yet doing its job.
The things reviewers change most often are the things the practice should teach next. A quarterly look at the pattern of QA changes is the cheapest training needs analysis there is.
Set turnaround targets for write-up, QA and issue, and timings for review reminders.
A fire risk assessment is a legal record as much as a piece of advice. This guide sets out a workflow that takes a practice from instruction to an issued, defensible report, at the volume a working practice has to handle.
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Bring us your assessor list and the building types you cover and we will show you what the competence matrix, the scheduler check and the QA stage look like on a real instruction.
