New tenants, altered layouts, different working practices or a few e-bikes charging in the corridor. Your building might have changed considerably over the past twelve months. But when was your last fire risk assessment review, and does it still reflect what’s actually happening in your building today?
Think back to when your building was last assessed for fire safety.
Perhaps it was twelve months ago. The fire risk assessor visited, inspected the premises, spoke to the manager and produced a report with recommendations for improving fire safety.
You reviewed the findings, arranged the necessary work and filed the assessment away.
Everything seemed reasonably straightforward.
But what’s happened in the building since then?
Perhaps somebody has divided a large office into smaller meeting rooms. A new tenant has moved into the second floor, additional staff have been recruited or a storage cupboard has gradually filled with equipment that nobody knows where else to put.
Maybe employees have started charging e-bike batteries in the staff room, or the fire marshal who used to organise evacuations left the company six months ago.
Individually, these changes might not seem particularly important.
But they could affect how a fire starts, how it spreads, whether the alarm provides adequate warning or how safely people can escape.
The problem is that your fire risk assessment doesn’t automatically know when something changes.
It records the building, its occupants, activities and fire safety arrangements as they were understood when the assessment was undertaken. Unless changes are identified and considered, the document can gradually become less representative of the premises it’s supposed to protect.
So how do you know when your fire risk assessment needs updating, and what changes should you be looking for?
When Does a Fire Risk Assessment Need Reviewing?
Under Article 9(3) of the Regulatory Reform (Fire Safety) Order 2005, the Responsible Person must review the fire risk assessment regularly to keep it up to date.
The legislation specifically requires a review where there is reason to suspect the assessment is no longer valid or where there has been a significant change in the matters to which it relates.
That includes changes to the premises, working arrangements, fire safety measures or the organisation of activities within the building.
The law doesn’t prescribe a universal twelve-month interval for every fire risk assessment.
However, the Home Office’s guidance for people with fire safety responsibilities recognises annual reviews as good practice for small, straightforward premises.
More complicated or higher-risk buildings may require a different review programme.
But there’s an important distinction between a scheduled review and a review triggered by a significant change.
If you install new machinery, substantially alter the layout or introduce a new fire hazard in March, you shouldn’t automatically wait until the annual review in November.
The effect of the change should be considered when it occurs, and preferably before changes are implemented where they could affect fire safety.
Does Every Change Mean You Need a Completely New Fire Risk Assessment?
Not necessarily.
The Home Office explains that a review doesn’t always involve carrying out an entirely new assessment.
Sometimes the existing assessment remains suitable, and the review simply establishes that previous recommendations have been completed, fire precautions remain effective and no significant new risks have been introduced.
Other changes may require particular sections of the assessment to be revised.
For example, moving a few desks around an office may have little effect on fire safety, provided escape routes remain clear and the existing precautions remain suitable.
But constructing new partitions, creating additional rooms or changing how parts of the building are used may affect detector coverage, travel distances or the effectiveness of fire-resisting construction.
Those changes need more careful consideration.
Where extensive alterations or significant new hazards have been introduced, commissioning a new fire risk assessment may be the most appropriate approach.
The question isn’t simply how old your assessment is. It’s whether the assessment still accurately reflects the building and the risks that exist today.
Have You Changed the Building’s Layout?
This is one of the most common reasons for reviewing an existing fire risk assessment.
An office might have been divided into several smaller rooms, a warehouse may have introduced high-level racking, or a retail business might have changed its shelving and stock arrangements.
These changes are often undertaken for perfectly sensible business reasons.
But they can affect fire safety.
New partitions may obstruct smoke detectors or create areas that aren’t adequately covered by the existing fire alarm. Altered layouts may increase travel distances, change escape routes or create rooms where people could become isolated during a fire.
New storage arrangements may introduce additional combustible materials or obstruct access to firefighting equipment.
The Home Office’s fire risk assessment guidance for offices and shops specifically identifies alterations to internal layouts, changes to furniture and significant increases in stock as reasons to review an assessment.
If your building has undergone alterations since the last assessment, it’s worth asking whether anybody considered their effect on the existing fire safety arrangements.
Have New Tenants Moved Into the Building?
Multi-occupied buildings can change considerably without any major construction work.
An office suite that previously accommodated a small professional services company might now be occupied by a business with more employees, different working hours or additional equipment.
A retail unit might have changed from a clothing shop to a restaurant, introducing commercial cooking equipment, extraction systems and new fire hazards.
Even a seemingly straightforward change of tenant can affect the building’s fire safety management.
The new occupier needs to understand the emergency procedures, shared escape routes, fire alarm arrangements and responsibilities for maintaining equipment.
Under Article 22 of the Fire Safety Order, Responsible Persons who share premises or have duties relating to them must cooperate and coordinate their fire safety measures.
They must also communicate relevant risks arising from their activities.
A landlord’s fire risk assessment might remain suitable for the communal staircase, but that doesn’t automatically mean it adequately considers the implications of a new tenant’s activities.
This is particularly important in mixed-use buildings containing shops, restaurants, offices or residential accommodation.
A change in one occupancy can affect the fire risks experienced by people elsewhere in the building.
Has the Number of People in the Building Changed?
Perhaps your business has grown.
The office that accommodated twelve people last year now has twenty-five employees, with additional desks fitted into every available space.
Or a restaurant has increased its seating capacity without reviewing the available escape routes.
Occupancy levels matter because the number of people present can affect the adequacy of escape routes, exit widths, evacuation arrangements and fire safety management.
The assessment also needs to reflect how the building is actually used.
A business that previously operated during normal office hours might now have evening shifts, weekend working or employees working alone.
Those arrangements can affect the availability of people appointed to assist with evacuation.
Under Article 15 of the Fire Safety Order, the Responsible Person must establish suitable emergency procedures and nominate sufficient competent people to implement evacuation arrangements.
A list of fire wardens prepared two years ago isn’t much use if half of them have left the business.
The arrangements should reflect the staffing levels and working patterns that exist today.
Have New Fire Hazards Been Introduced?
Not every significant change involves construction work or additional occupants.
Sometimes the biggest changes come from new equipment or working practices.
A workshop might have introduced welding, grinding or spray-finishing activities. A restaurant may have installed additional cooking equipment. A warehouse could now be storing different goods, including flammable liquids or materials that create greater fire loads.
These changes can introduce new ignition sources, increase the potential for fire spread or require additional protective measures.
The existing fire risk assessment may not have considered them.
Where dangerous substances are introduced, additional assessments and precautions may also be necessary, including consideration of the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR).
The important point is that changes in business operations need to be communicated to whoever manages fire safety.
A facilities manager may know that new equipment has been installed, but unless the information reaches the Responsible Person or fire risk assessor, the implications may never be properly considered.
What About E-Bikes and E-Scooters Being Charged at Work?
This is a particularly relevant example of how new fire hazards can appear without anybody making a formal decision to change the building’s use.
Perhaps an employee starts commuting on an e-bike and asks to charge the battery at work.
Initially, one battery is plugged into a socket in the staff room. A few months later, several employees are charging batteries, and somebody has started leaving an e-scooter near the rear exit.
Nobody has deliberately introduced a new fire hazard as part of a business project.
But the fire risk has changed.
Lithium-ion batteries can present serious hazards if they are damaged, defective, incorrectly charged or modified.
In August 2026, BBC Verify reported that Freedom of Information responses from UK fire and rescue services identified more than 2,000 fires involving e-bikes, e-scooters or their batteries between 2019 and 2025, with 18 fatalities recorded during that period.
The figures demonstrate why battery storage and charging arrangements deserve proper attention.
The government’s guidance on managing e-bike and e-scooter fire risks in premises specifically identifies the introduction of these hazards as a reason to review the fire risk assessment.
The guidance highlights the importance of suitable storage and charging locations, avoiding escape routes and considering the potential consequences of a battery fire.
The Office for Product Safety and Standards also advises against charging batteries unattended or storing and charging them where they could obstruct an escape route.
If employees, tenants or residents have started charging e-bike batteries in your premises, that change needs to be considered.
The solution isn’t necessarily a blanket prohibition on every electric bicycle. Suitable arrangements should be based on the premises, the users and the risks.
But an unofficial charging station beside an escape door is not something to leave until the next scheduled assessment.
Have Your Fire Safety Arrangements Changed?
Buildings can change in less obvious ways too.
Perhaps your security contractor has installed a new access control system, or the facilities team has replaced several fire doors with electronically controlled doors.
These changes may affect how people escape during an emergency and whether doors release correctly when the fire alarm operates.
Even changes that appear to improve security can create fire safety problems if they’re not properly designed and assessed.
Similarly, a new ceiling, ventilation system or electrical installation may affect fire detection or the building’s fire-resisting construction.
Contractors installing cables and pipework may create openings through compartment walls or floors that require appropriate fire-stopping.
The work might be hidden above ceilings or inside service cupboards, making it difficult to identify during a routine walk-through.
This is why fire safety needs to be considered before alterations begin, not simply when the next assessor arrives.
There should be suitable arrangements for reviewing proposed work, approving changes and retaining evidence that relevant fire safety precautions have been maintained.
Has Anyone’s Ability to Evacuate Changed?
Fire risk assessments need to consider the people using the premises, not simply the building itself.
An employee might develop a mobility impairment, somebody may return to work following an injury, or a new member of staff may require assistance during an evacuation.
These circumstances can affect whether the existing emergency arrangements remain suitable.
Employers and other relevant dutyholders should provide a confidential way for people to raise evacuation concerns and arrange appropriate assistance where necessary.
That may involve a Personal Emergency Evacuation Plan (PEEP) or other suitable arrangements based on the person’s needs and the building.
The objective is to ensure people can evacuate safely, rather than waiting until a fire drill reveals that the existing procedure doesn’t work for somebody.
Not every personal change requires an entirely new fire risk assessment, but changes affecting evacuation arrangements should be considered and documented appropriately.
Who Should Tell the Fire Risk Assessor What’s Changed?
This is where fire safety management can become surprisingly difficult.
The fire risk assessor doesn’t automatically know what’s been happening in the building since the last assessment.
They might observe a new partition or additional storage during their next visit, but they won’t necessarily know that a tenant has sublet part of its premises, a fire warden has left or a contractor installed cabling through a compartment wall several months earlier.
Different departments often hold different pieces of information.
Human resources knows about changes in staffing. Facilities managers know about building alterations. Operations managers understand new equipment and working practices. Landlords and managing agents know about tenancy changes.
But unless that information is collected, important changes may never reach the person responsible for reviewing fire safety.
At ESI: Fire Safety, we recommend having a clear process for identifying and communicating changes that could affect the fire risk assessment.
That doesn’t need to be complicated. A nominated person can maintain a record of relevant changes, with managers and contractors required to report alterations or new risks as they arise.
The information should then be considered promptly and provided to the fire risk assessor where appropriate.
Which Changes Need an Immediate Review?
Not every minor change requires a new assessment, but the Responsible Person needs a sensible way of deciding what matters.
A useful starting point is to consider whether the change affects how a fire could start, how quickly it could spread, how people would be warned or whether they could escape safely.
Changes in occupancy, working arrangements or the effectiveness of fire precautions should also be considered.
For example, introducing a new spray-finishing process, removing fire-resisting construction or converting a storeroom into sleeping accommodation would clearly require careful assessment.
Moving a filing cabinet within an office, without affecting escape routes or other precautions, may not have the same significance.
However, a seemingly minor change could become important when considered alongside other alterations.
Where a significant change has occurred, or there’s reason to suspect the existing assessment is no longer valid, Article 9 requires a review and any necessary revisions.
If you’re uncertain whether a proposed change is significant, obtaining competent advice before proceeding is usually preferable to discovering a problem afterwards.
Why Is It Important to Record Changes and Reviews?
Good records provide evidence that fire safety is being actively managed.
Since October 2023, changes introduced through Section 156 of the Building Safety Act 2022 require Responsible Persons to record their fire risk assessments in full, including the findings of reviews, regardless of the number of employees.
They must also record their fire safety arrangements.
Maintaining a dated record of changes to the building helps support those duties.
For example, if new partitions have been installed, the record might include the date, a description of the work, relevant drawings, any fire alarm alterations and evidence that necessary fire safety measures were checked.
Where changes are found to have no material effect on the existing assessment, it’s useful to record that conclusion and the reason for it.
Where a review identifies deficiencies, the resulting actions should be documented and evidence of completion retained.
A review record that simply says “no changes” isn’t particularly reassuring if the building has been altered substantially since the previous assessment.
The purpose of record keeping isn’t to create paperwork for its own sake. It’s to demonstrate that changes have been recognised, considered and properly managed.
That evidence can be valuable during fire and rescue service inspections, insurance enquiries and future fire risk assessments.
Make Fire Safety Reviews Part of Normal Building Management
One of the simplest improvements a business can make is to stop treating fire risk assessments as an isolated annual event.
Instead, consider fire safety whenever changes are proposed.
If the facilities team is planning new partitions, ask whether they affect detector coverage or escape routes.
If operations is introducing new equipment, consider whether it changes the fire hazards.
If a managing agent appoints a new tenant, ensure the relevant fire safety information is shared.
And when HR recruits new staff or changes working arrangements, check whether the evacuation procedures and nominated personnel remain suitable.
These questions can be built into normal management meetings, contractor approvals and refurbishment processes.
It’s far easier to identify a fire safety issue while work is being planned than to discover it six months later and have to put the work right.
Is Your Fire Risk Assessment Still Up to Date?
A fire risk assessment shouldn’t be treated as a document that’s completed, filed away and forgotten until somebody reminds you that it’s due for renewal.
It needs to reflect the building as it is actually used.
Over twelve months, a great deal can change. New tenants arrive, layouts are altered, staff move on and new equipment is introduced.
Individually, those changes may seem ordinary. Collectively, they can affect the assumptions on which the original assessment was based.
The important thing is to recognise when changes influence fire safety and make sure they’re considered appropriately.
Some may require nothing more than a documented review. Others may justify amendments, additional precautions or a completely new assessment.
The real question isn’t whether your fire risk assessment is twelve months old. It’s whether it still describes the building you’re responsible for today.
Fire Risk Assessment Reviews from ESI: Fire Safety
At ESI: Fire Safety, we help businesses, landlords, facilities managers and managing agents keep their fire risk assessments up to date as buildings, occupants and working practices change.
We undertake fire risk assessments and compliance reviews for offices, shops, restaurants, warehouses and commercial properties in Camberley, Farnborough, Fleet, Woking, Guildford, Bracknell and Reading, as well as surrounding towns.
Whether you’ve refurbished your premises, taken on new tenants, introduced additional equipment or changed how your building is used, we can assess whether your existing fire risk assessment remains suitable and identify any additional precautions needed.
ESI: Fire Safety — No Shortcuts in Safety.
Contact ESI: Fire Safety or call 01276 300 351 to arrange a fire risk assessment review.
This article focuses on fire safety legislation applicable in England and Wales. The need for a review depends on the premises, the changes involved and their potential effect on fire safety.
