Your contractor has finished the refurbishment, the building looks fantastic and the keys are ready. But where are the fire alarm certificates, fire door specifications, compartmentation drawings and operating instructions? Fire safety information at handover is essential if you’re going to manage your building properly. Here’s what you should be asking for before signing off the work.
Imagine you’ve just spent £250,000 refurbishing a commercial building.
The contractor has completed the work, the new fire alarm has been installed and the premises are ready for occupation.
You’re handed a folder containing electrical certificates, a few equipment manuals and some drawings.
Everything appears to be in order.
Six months later, your fire risk assessor asks for the fire strategy, fire door specifications and compartmentation drawings.
You discover that nobody can find them.
The fire alarm company has changed, the contractor has moved on to another project and the architect’s drawings don’t reflect everything that was actually installed.
Now you’re paying people to investigate work you’ve already paid to have completed.
It’s a frustrating situation, and one that can be avoided.
A completed building isn’t necessarily a properly handed-over building.
The person responsible for managing the premises needs enough information to understand how its fire safety arrangements work, what equipment has been installed and what needs to be maintained.
In certain circumstances, providing this information is a specific legal requirement under Regulation 38 of the Building Regulations 2010.
But even where that particular regulation doesn’t apply, building owners, landlords, managing agents and commercial tenants should make suitable fire safety documentation a clear part of their construction contracts.
What Is Fire Safety Information at Handover?
Fire safety information at handover is the documentation needed to understand, operate and maintain the fire safety arrangements provided within a building.
It helps the person taking responsibility for the premises understand what has been constructed and how the different fire protection measures are intended to work together.
This might include the building’s fire strategy, as-built drawings, fire alarm specifications, emergency lighting information, fire door schedules, compartmentation details and maintenance instructions.
However, it’s not simply a collection of certificates.
Imagine a mixed-use building containing shops at ground-floor level and residential flats above.
The fire strategy might rely on the commercial and residential areas being adequately separated, with different fire alarm and evacuation arrangements.
If the managing agent doesn’t have that information, how can they be confident that later alterations won’t compromise the original design?
The same applies to a warehouse where a compartment wall separates hazardous manufacturing activities from adjoining office accommodation.
Knowing that a fire-resistant wall exists is useful. Understanding its location, intended fire resistance and the restrictions on making new service penetrations is considerably more useful.
That’s the purpose of a proper fire safety handover.
It gives future owners, occupiers, contractors and fire risk assessors the information necessary to maintain the protection that the building was designed to provide.
What Does Regulation 38 of the Building Regulations Require?
Regulation 38 of the Building Regulations 2010 establishes a legal requirement to provide fire safety information in specified circumstances.
In England, it applies where building work involves the erection or extension of a relevant building, or work connected with a relevant material change of use, and the fire safety requirements of Part B apply.
A relevant building is one to which the Regulatory Reform (Fire Safety) Order 2005 applies, or will apply following the work.
The person carrying out the building work must provide the relevant fire safety information to the Responsible Person.
The information must be sufficient to help the Responsible Person understand, operate and maintain the building and its fire safety arrangements with reasonable safety.
When Must the Information Be Provided?
The timing depends on whether the building remains occupied during the work.
Where the building or extension is unoccupied during the work, the information must be provided by completion or first occupation, whichever comes first.
Where the building remains occupied during the work, the deadline is completion.
This is important for landlords and developers planning to hand over newly completed premises.
Fire safety information shouldn’t be treated as an optional administrative exercise to be dealt with several months after occupation.
If the building is ready for people to use, the people responsible for its fire safety need the relevant information.
Do You Have to Sign to Confirm You’ve Received the Information?
Since October 2023, Regulation 38 has included additional requirements concerning acknowledgement of the fire safety information.
In England, the Responsible Person must give the person carrying out the work a notice acknowledging receipt and confirming that the information is sufficient to enable them to understand, operate and maintain the building and its fire safety systems.
That creates an important practical question.
Should you sign a declaration confirming that the handover information is sufficient when you haven’t checked what’s actually been provided?
We wouldn’t recommend doing so.
Receiving a folder of documents is not the same as confirming that the information adequately explains the building’s fire safety arrangements.
If documents are missing, outdated or inconsistent with the completed work, those issues should be identified and raised.
The person carrying out the work is normally required to notify the relevant building control authority about the handover within five days of the applicable Regulation 38 deadline.
Different notification periods apply under specified self-certification and third-party certification arrangements.
Importantly, the legislation also addresses situations where the contractor hasn’t received the Responsible Person’s acknowledgement. The contractor must report the steps taken to obtain it.
This means withholding an acknowledgement doesn’t automatically prevent the contractor from making the required notification.
Nevertheless, the Responsible Person should take the declaration seriously.
If you’re uncertain whether the information is sufficient, obtain clarification or competent technical advice before confirming something you cannot reasonably verify.
Does Regulation 38 Apply to Every Refurbishment or Fit-Out?
No, and this is where misunderstandings can arise.
Regulation 38 has a defined scope. It doesn’t automatically apply to every refurbishment, alteration or commercial fit-out.
For example, a landlord may undertake work that involves moving internal partitions, replacing fire doors or altering a fire alarm without erecting or extending the building or carrying out a relevant material change of use.
Such work may still be subject to other Building Regulations requirements, but it doesn’t necessarily trigger Regulation 38.
That doesn’t mean documentation is unnecessary.
Imagine a tenant fitting out a commercial office.
The contractor alters the fire alarm, installs new partitions and changes several fire doors.
Even if the particular work doesn’t trigger Regulation 38, somebody still needs to know what was changed.
Otherwise, future maintenance contractors may not have the information necessary to maintain the systems properly.
There may also be duties to review the fire risk assessment, maintain fire protection equipment and coordinate fire safety arrangements with other Responsible Persons.
Our advice is straightforward.
Include appropriate fire safety handover requirements in every substantial refurbishment or fit-out contract, whether or not Regulation 38 applies.
Don’t rely solely on the minimum statutory handover requirements to establish what the contractor must provide.
What Documents Should You Ask Your Contractor to Provide?
The exact documents will depend on the building and the work undertaken.
A small restaurant refurbishment won’t require the same level of technical documentation as a new multi-storey commercial development.
However, the March 2025 amendments to Approved Document B provide useful guidance on the essential information required and additional information appropriate for complex buildings.
Section 17 explains that the information should enable the relevant dutyholder to understand, operate and maintain the building, including its fire safety systems.
It should also explain how the various fire safety arrangements are intended to work together.
The following documents are among those we recommend considering when preparing a project handover specification.
1. The Fire Strategy
Where a fire strategy has been prepared, it should form part of the handover information.
The fire strategy explains the principles behind the building’s fire safety design.
It may establish the intended occupancy, escape arrangements, evacuation strategy, compartmentation, fire detection and firefighting provisions.
This information is particularly important where a design relies on specific management arrangements.
For example, a building may have been designed around an occupancy limit, particular evacuation procedures or a smoke control system supporting an escape route.
If the Responsible Person doesn’t know about those assumptions, they may unintentionally undermine the design.
The strategy should reflect the building as completed, including relevant changes made during construction.
If the final installation differs materially from the original design, the project team should explain how those changes have been assessed and incorporated into the final fire safety information.
2. Accurate As-Built Drawings
An as-built drawing should describe what was actually constructed rather than simply what the architect originally intended.
For fire safety purposes, the drawings should identify the relevant escape routes, fire-resisting construction, fire doors and fire protection systems.
For example, a compartmentation drawing should show the locations of fire-resisting walls and floors, including their intended performance where relevant.
That matters when somebody subsequently wants to run new cables, install ventilation equipment or alter internal partitions.
Without accurate drawings, a contractor may unknowingly penetrate a compartment wall or remove an important fire-resisting element.
Approved Document B also identifies information concerning emergency lighting, fire detection equipment, firefighting facilities, smoke control and sprinkler systems.
The level of detail should reflect the actual building and the protection installed.
3. Fire Alarm Documentation and Cause-and-Effect Information
A fire alarm commissioning certificate is important, but it’s not necessarily the whole story.
You should also have sufficient information to understand the type of system installed, its detection coverage, zoning, operating arrangements and maintenance requirements.
For addressable systems, appropriate device and configuration information can be particularly useful.
Where the fire alarm interacts with other equipment, the cause-and-effect arrangements need to be documented.
Imagine a restaurant where the fire alarm is connected to door-release devices, ventilation controls and other safety systems.
Or a residential block where smoke detection operates automatic smoke vents on particular floors.
The future maintenance contractor needs to understand what should happen when the system activates.
Without suitable information, it can be difficult to establish whether the connected systems are operating correctly.
We recommend requesting the relevant commissioning and installation certificates, zone information, user instructions, maintenance requirements and cause-and-effect documentation appropriate to the installation.
4. Emergency Lighting Information
Emergency lighting is another system where important information can disappear after installation.
The Responsible Person should have appropriate completion and commissioning documentation, together with information identifying the equipment, test arrangements and maintenance requirements.
Depending on the installation, this may include layout drawings, system information and the relevant test records.
This is particularly useful when a new maintenance contractor is appointed.
It also helps prevent confusion about which luminaires form part of the emergency lighting system and how they should be tested.
5. Fire Door Schedules and Product Information
Fire doors are a common source of problems after refurbishment work.
A contractor might install several new doors and provide a general statement that they are FD30S.
But which doors were installed where? What assemblies were supplied? Were existing frames retained? What hardware is permitted?
A useful handover should identify the fire doors installed, their intended performance and the supporting information necessary for ongoing maintenance.
Where appropriate, request a door schedule, relevant classification or other performance evidence, installation records and maintenance instructions.
A fire door’s performance depends on the complete assembly, including its frame, seals, hinges, closers and other hardware.
The information should therefore be sufficient to identify suitable repairs and avoid inappropriate future alterations.
This becomes particularly important when locksmiths or security contractors are later asked to change locks, access controls or closing devices.
6. Compartmentation and Fire-Stopping Records
Fire-stopping is one of the areas where a good handover can save considerable expense later.
During construction, contractors may install hundreds of cables, pipes and services through fire-resisting walls and floors.
Each relevant penetration needs an appropriate fire-stopping arrangement.
But once ceilings are closed and service risers are enclosed, much of this work can become difficult to inspect.
The Association for Specialist Fire Protection (ASFP) publishes guidance on the specification, installation and inspection of passive fire protection.
Its guidance on fire-stopping highlights the importance of installation records, traceability and photographic evidence.
We recommend asking for records showing the locations of relevant fire-stopping installations, the systems used and the supporting installation evidence.
Photographs taken before works are concealed can be particularly valuable.
Not every project is subject to an identical statutory requirement for photographic records of every penetration. However, specifying suitable evidence in the contract can help prevent expensive uncertainty after completion.
7. Smoke Control and Other Specialist Systems
Where a building has automatic opening vents, smoke shafts, mechanical smoke extract, sprinklers or other specialist fire protection systems, the handover information should reflect those installations.
This includes their intended operation, controls, maintenance requirements and relevant commissioning records.
Smoke control systems are a particularly good example.
A managing agent may know that automatic vents are installed but have no information explaining which vents should open when smoke is detected on a particular floor.
If the system develops a fault, the maintenance contractor needs to know what correct operation looks like.
For more complex buildings, Approved Document B specifically recommends detailed information about the design and operation of these systems.
That information should be available before the building is occupied and managed.
Why Does the Difference Between As-Designed and As-Built Matter?
Imagine a developer provides a fire strategy prepared during the early design stages.
It specifies a particular smoke control system, compartmentation arrangement and fire alarm configuration.
During construction, the contractor makes several changes.
A fire door is moved, the alarm system is altered and a different smoke ventilation arrangement is installed.
The final handover pack still contains the original drawings and strategy.
On paper, the building appears to have one set of fire precautions. In reality, something different has been installed.
This creates obvious problems for future maintenance and fire risk assessment.
The person reviewing the building may be relying on assumptions that no longer apply.
The issue isn’t necessarily that every change was inappropriate. Designs often develop during construction.
The problem is when those changes aren’t properly assessed, authorised where necessary and recorded.
The handover documents should describe the building you’ve received, not the building somebody originally intended to construct.
For significant projects, we recommend asking the project team to identify relevant design changes and confirm how the final fire strategy and supporting documentation reflect the completed installation.
What Should You Check Before Accepting a Fire Safety Handover Pack?
You don’t need to become a fire engineer to identify some common omissions.
Start by establishing whether the documents you’ve received actually relate to the building and work undertaken.
Are the drawings marked as as-built, or are they preliminary tender drawings?
Does the fire door schedule identify the doors installed? Do the fire alarm zone plans match the labels and equipment in the building?
Have the commissioning certificates been provided for the systems installed?
Are the relevant operating instructions and maintenance schedules available?
If a fire strategy was prepared, does it reflect the final building and its intended use?
For more complex premises, consider commissioning an independent review of the fire safety handover documents.
A competent consultant can compare the available information with the building, identify significant gaps and recommend further verification where necessary.
This doesn’t automatically mean every installation needs to be dismantled or subjected to an intrusive investigation.
The appropriate level of checking should reflect the project’s complexity and the evidence available.
However, where substantial systems or fire-resisting construction are involved, it can be sensible to arrange appropriate inspections during the work rather than leave everything until completion.
Should You Make Fire Safety Documentation a Contract Requirement?
Yes. For substantial building work, we’d recommend doing this before the contractor is appointed.
The contract should identify the fire safety information required, the party responsible for providing it and the format in which it must be supplied.
For example, you might require a coordinated electronic handover pack containing the applicable fire strategy, as-built drawings, fire safety system documentation, commissioning records, door schedules and maintenance information.
You should also establish who will review the documents and how any omissions will be resolved.
Where appropriate, the contract can make satisfactory delivery of defined handover documents a condition of practical completion or release of specified payments, subject to the agreed contract terms and legal advice.
This needs to be properly incorporated into the appointment rather than introduced after a dispute develops.
The advantage of agreeing the requirements early is that contractors can collect the necessary records as work progresses.
Fire-stopping photographs, commissioning information and installation details are considerably easier to assemble during construction than months after the work has been covered up.
What if the Landlord and Tenant Have Different Fire Safety Responsibilities?
Multi-occupied buildings can make handover more complicated.
Imagine a tenant commissions a fit-out within a commercial building.
The tenant controls its own workplace, while the landlord manages the shared staircase, common fire alarm or other building-wide fire precautions.
The tenant’s contractor may have altered equipment that affects the landlord’s systems.
Who receives the information?
Where Regulation 38 applies, the statutory handover must be made to the relevant Responsible Person.
However, it may also be necessary for other parties to receive information about changes affecting the fire safety measures under their control.
Under Article 22 of the Fire Safety Order, relevant Responsible Persons must cooperate and coordinate their fire safety arrangements.
For practical purposes, we recommend agreeing information-sharing responsibilities before the work begins.
The tenant should understand the fire precautions within its premises, while the landlord or managing agent needs sufficient information about changes affecting the wider building.
This is particularly important where the premises share an escape route, fire alarm or other common life safety system.
Why Does the Handover Pack Matter to Your Fire Risk Assessment?
A fire risk assessment is based on the building’s actual use, construction, hazards and fire precautions.
If significant building work has changed those matters, the assessment needs to be reviewed.
Under Article 9(3) of the Fire Safety Order, fire risk assessments must be reviewed regularly and particularly where significant changes have occurred.
The Home Office’s guidance for Responsible Persons explains that a review doesn’t always mean starting again with an entirely new assessment.
However, significant refurbishment, extensions, changes of use or alterations to fire protection measures may justify a more substantial review.
The fire risk assessor needs to understand what has changed.
For example, if a warehouse has been divided into separate occupancies, the assessor may need to establish the fire resistance of the new compartment walls and the arrangements for shared escape routes.
If an office has installed a new fire alarm, relevant commissioning and cause-and-effect information can help establish how it operates.
Accurate handover information allows the assessor to make better-informed judgements.
Without it, the report may need to record significant limitations or recommend additional investigation.
That’s one reason why a proper fire safety handover can save money over the longer term.
What Happens When the Building Changes Managing Agents?
The need to retain fire safety information doesn’t end when construction is completed.
Under Article 22A of the Regulatory Reform (Fire Safety) Order 2005, an outgoing Responsible Person must provide relevant fire safety information to the incoming Responsible Person.
This includes information received under Regulation 38.
The duty is important when buildings are sold, businesses change ownership or responsibility for a premises transfers.
For managing agents and RTM companies, it reinforces the importance of keeping organised building records and ensuring that the relevant Responsible Person can access them.
A new managing agent shouldn’t have to spend months reconstructing the fire safety history of a building.
The original fire strategy, relevant drawings, inspection records and system documentation should remain available to support continued fire safety management.
Do Higher-Risk Buildings Have Different Handover Requirements?
Yes.
Higher-risk buildings in England are subject to additional requirements under the Building Safety Act framework and the Building (Higher-Risk Buildings Procedures) (England) Regulations 2023.
These include specific requirements concerning building control approval, completion and the transfer of relevant building safety information.
The arrangements form part of the wider golden thread approach to recording and managing building safety information.
Projects involving higher-risk buildings should therefore be assessed against their applicable statutory procedures rather than relying solely on the general Regulation 38 process described here.
The relevant project team should establish those requirements before work begins.
What Should You Do if Important Fire Safety Documents Are Missing?
First, identify what’s actually missing and why the information matters.
A missing maintenance manual is different from being unable to establish whether the main escape staircase has the intended fire-resisting separation.
Contact the original contractor, designer, installer or developer and request the relevant information.
Check whether the documents may be held by building control, a previous managing agent or an existing maintenance company.
Where documentation cannot be recovered, it may be possible to obtain replacement information from manufacturers or system providers.
However, that won’t always establish what was actually installed.
In more complicated cases, a competent specialist may need to inspect the relevant systems or construction and determine whether further investigation is necessary.
A retrospective fire strategy review or fire risk assessment may also help identify the implications of missing information.
The aim should be to establish which records are genuinely important and what evidence is necessary to demonstrate that the building’s fire safety arrangements remain suitable.
You don’t necessarily need to reconstruct every historical document, but you do need enough reliable information to manage the building safely.
Fire Safety Handover: What Should Building Owners Remember?
When a construction project finishes, the building owner or Responsible Person needs more than the keys and a collection of certificates.
They need to understand how the building is intended to operate, which fire protection measures have been installed and what must be maintained.
Regulation 38 establishes a specific legal handover duty for certain building work.
Approved Document B provides further guidance on the information that should be supplied, particularly where complex fire protection systems are involved.
But even where Regulation 38 doesn’t apply, appropriate handover documentation remains an important part of responsible building management.
The best approach is to establish the requirements before work begins, collect evidence throughout construction and check the final information before accepting it as complete.
Otherwise, the cost of missing information may fall on the building owner, managing agent or occupier long after the contractor has finished.
A good fire safety handover should leave you knowing what has been installed, why it’s there and how to keep it working—not wondering who has the drawings.
Need Independent Fire Safety Consultancy or Handover Support?
At ESI: Fire Safety, we help property owners, developers, landlords, letting agents, RTM companies and managing agents understand the fire safety arrangements within their buildings.
Our services include fire safety consultancy, fire risk assessments, fire strategy reviews, fire door inspections and compartmentation surveys.
We can review existing fire safety documentation, identify significant information gaps and advise where further technical investigation may be necessary.
For refurbishment and conversion projects, we can also help clients consider the fire safety implications before work begins and review whether the information provided at completion is suitable for ongoing management.
Through our Dedicated Fire Safety Manager service, we provide ongoing support with fire safety records, maintenance programmes, contractor coordination and monitoring outstanding compliance actions.
This can be particularly useful for managing agents and RTM companies responsible for multiple buildings or developments involving several different occupiers.
Our consultancy services cover residential blocks, offices, restaurants, commercial developments, warehouses and mixed-use buildings across Surrey, Hampshire, Berkshire, Sussex, Kent, Oxfordshire and South West London, including Chertsey, Fareham, Bracknell, Lewes, Tunbridge Wells, Didcot and Wimbledon.
Whether you’re planning a refurbishment, approaching practical completion or struggling to obtain the information necessary to manage an existing property, we can help establish the next steps.
ESI: Fire Safety — No Shortcuts in Safety.
Contact ESI: Fire Safety, call 01276 300 351 or email office@esifiresafety.co.uk to discuss your fire safety consultancy or ongoing management requirements.
This article primarily addresses the fire safety information requirements applicable to relevant building work in England. Regulation 38 has a defined statutory scope, and separate higher-risk building procedures may apply. The information required for a particular project should reflect its complexity, the work undertaken and the applicable building control and contractual requirements.
