A long action plan is not a to-do list to be ticked off from the top.
It is a description of the fire risk in your building.
How you prioritise, assign, verify and feed back those actions decides whether the building is actually safer, or whether the spreadsheet just looks better.
The short answer
Don’t start at action 1 and work down, and don’t measure progress by how many rows have turned green.
Treat the list as a description of the risk in your building.
Find the few that carry real life-safety weight and deal with them first, with interim measures where the fix will take time.
Give every action a named owner and a realistic date.
Close each one on evidence, not on an instruction to a contractor.
Check what each fix disturbs.
Then bring the fire risk assessment up to date.
What the law asks for
Since 1 October 2023, Article 9 of the Fire Safety Order (as amended by section 156 of the Building Safety Act 2022) has required the record of the assessment to include its findings, “including the measures which have been or will be taken”.
Government guidance on section 156 says the whole assessment, with all its findings, must now be recorded in every case.
Article 11 requires arrangements for the “effective planning, organisation, control, monitoring and review” of the preventive and protective measures. The Home Office guide for dutyholders adds that significant findings “must be actioned within the designated period specified”.
The law doesn’t prescribe a format for an action plan. In our view, though, a plan that nobody owns or monitors is hard to square with Article 11.
Read the list as a risk picture
Twenty-five actions rarely means 25 separate problems. Five door items on one corridor are usually one job for one contractor. Group them first.
Then separate the handful that carry life-safety weight from the housekeeping.
An escape stair that isn’t adequately protected, missing detection in a sleeping area, or a door that won’t close onto the only protected route belongs in a different category from a missing “keep shut” sign or a gap in the log book. The assessor’s priority ratings are your starting point. If the report doesn’t make that clear, ask.
Owner, date and interim measures
Each action needs a named person, not “management” or “the landlord”, and a date that matches its priority.
Where the fix takes weeks, such as a new door set or an alarm upgrade, decide what happens meanwhile: clearing combustibles from the route, taking a room out of use, or increasing checks. Record the interim measure and who agreed it.
If budget forces phasing, phase by risk, write the reasoning down, and ask the assessor whether the interim position is acceptable. Phasing that quietly turns into indefinite deferral is where Responsible Persons get into difficulty.
Close on evidence, not instruction
“Contractor instructed” or “order raised” does not mean complete. This is where spreadsheets mislead: a row turns green when someone types “done”, and nobody looks at the wall.
We’d expect dated photographs showing the location, a certificate or commissioning record for any system work, an invoice that says what was done and where, and for anything significant, a re-inspection by someone competent. Once a ceiling goes back, fire-stopping is only as reliable as the photograph taken before it was hidden.
Check the knock-on effects
Remedial work changes the building.
A replacement fire door needs a compatible frame, correct gaps, the right seals, a working self-closer and signage, and the wall around it still has to be fire-resisting.
Adding detectors can change the alarm system’s category, cause and effect, and zone plan.
A new partition can lengthen a travel distance, create a dead end or leave part of a corridor without emergency lighting.
Cables for new equipment can breach the compartment wall you have just had repaired.
Ask the contractor, and your assessor if in doubt, what else each change affects.
Feed it back into the assessment
As significant actions close, update the record so it shows what has been done, not just what was planned.
The Home Office guide notes that a review may simply check that action has been taken on the measures the previous assessment identified. Where the works are themselves a significant change to the premises, Article 9(3) requires a review.
If you disagree with an action
Don’t delete it.
Ask the assessor what they saw, where, and which part of the fire strategy it affects.
Sometimes a different measure achieves the same outcome for less money. Sometimes the action was generic and shouldn’t be there.
Record the decision and the reasoning.
An unexplained gap in an action plan is difficult to defend after a fire or an inspection.
