Should your fire risk assessment check the nearest public fire hydrant, confirm its water supply and make sure it’s maintained? The answer depends on who owns it, who’s responsible for it and whether it’s actually part of your building’s fire safety arrangements.
Imagine you’re reviewing the fire risk assessment for your office, restaurant, warehouse or block of flats, and you come across an action requiring you to confirm that the public fire hydrant outside the building has been tested and provides an adequate water supply.
It sounds reasonable enough. After all, firefighters might need that hydrant if there’s a fire, and having a reliable water supply is clearly important.
But there’s a problem.
You don’t own the hydrant, you don’t maintain it, and you’re not authorised to operate it or carry out a flow test. You probably don’t even know which water main supplies it.
So how exactly are you supposed to close that action?
It’s a question that’s attracted attention within the fire safety industry, particularly following the publication of BS 9792:2025, the British Standard code of practice for fire risk assessments in housing.
In April 2026, the Fire Industry Association (FIA) addressed this issue in its Mythbuster series, challenging the inclusion of public fire hydrant maintenance and capacity assessments in a building’s fire risk assessment.
But before we dismiss hydrants as somebody else’s responsibility, there’s an important distinction to make.
Public fire hydrants and private fire hydrants are not the same thing, and the responsibilities for inspecting, testing and maintaining them can be very different.
If your premises have a private hydrant system, there are recognised British Standard recommendations for regular maintenance and testing, and the records should be considered during your fire risk assessment.
Let’s look at what the law says, who is responsible for which equipment and what your fire risk assessor should actually be checking.
Should a Fire Risk Assessment Include Public Fire Hydrants?
For an ordinary public fire hydrant connected to the water company’s mains, the Responsible Person for a neighbouring building isn’t normally responsible for inspecting it, testing its water flow or arranging repairs.
Those duties sit elsewhere.
Under Section 57 of the Water Industry Act 1991, water undertakers have a statutory duty to keep fire hydrants installed on their water mains and other pipes in good working order, replacing them where necessary.
Meanwhile, Section 38 of the Fire and Rescue Services Act 2004 requires fire and rescue authorities to take reasonable measures to secure an adequate water supply for firefighting.
Fire and rescue authorities also have operational arrangements for locating, inspecting and testing public hydrants, working alongside the relevant water companies.
In other words, there’s already a statutory framework dealing with public firefighting water supplies.
It doesn’t transfer responsibility for maintaining the hydrant in the road to the owner of the shop, restaurant or block of flats next door.
This distinction matters because a fire risk assessment should identify relevant fire safety risks and the precautions needed to manage them. It shouldn’t routinely impose maintenance responsibilities on somebody who doesn’t own or control the equipment.
What Does the Fire Industry Association Say?
In April 2026, the FIA published Mythbuster 30: Fire Risk Assessments Should Consider the Location, Capacity and Maintenance of Public Fire Hydrants.
The FIA’s position is that recording the location, capacity and maintenance of public fire hydrants doesn’t provide a useful contribution to an ordinary fire risk assessment under Article 9 of the Regulatory Reform (Fire Safety) Order 2005.
Its reasoning is straightforward. The building’s Responsible Person doesn’t control the public hydrant, isn’t responsible for its maintenance and has no authority to undertake the necessary testing.
The FIA also points out that neither the Responsible Person nor the fire risk assessor will necessarily know how the fire and rescue service intends to obtain water when attending an incident.
Firefighters may have information about unsuitable hydrants, alternative water supplies or operational arrangements that aren’t available to somebody inspecting the building.
It’s a sensible argument.
However, it’s important to distinguish the FIA’s professional interpretation from the wording of BS 9792:2025, which the FIA has challenged.
And it doesn’t mean every issue involving a public hydrant is irrelevant. An obstruction caused by activities under the building owner’s control, for example, may still deserve attention.
Public or Private Fire Hydrant: What’s the Difference?
Before deciding whether a hydrant belongs in your fire risk assessment, you need to establish who is responsible for it.
A public hydrant is normally connected to the water company’s mains or other pipes, with maintenance responsibilities governed by the Water Industry Act.
A private fire hydrant may be installed on a privately owned water main serving an industrial estate, hospital, warehouse complex, residential development or another property.
These private systems may have been installed specifically to provide firefighters with a suitable water supply for the premises.
Where the property owner, managing agent or another dutyholder is responsible for maintaining the system, there should be appropriate arrangements for inspection, testing and repairs.
And there’s an important point about location.
A hydrant isn’t automatically private just because it’s inside the boundary of a commercial property.
Water company mains can cross privately owned land, and hydrants connected to those mains may remain the responsibility of the water undertaker.
Equally, a privately maintained fire main might serve several buildings, with maintenance responsibilities allocated through leases, management agreements or other arrangements.
The important questions aren’t simply where the hydrant is located, but who owns or controls the equipment, who is responsible for maintaining it and what role it plays in the building’s fire safety arrangements.
If those responsibilities aren’t clear, establishing them is a sensible starting point.
Do Private Fire Hydrants Have to Be Tested to BS 9990?
Yes, private fire hydrants should be subject to a suitable programme of inspection, testing and maintenance, with BS 9990:2015 providing the recognised British Standard recommendations.
BS 9990:2015 — Non-automatic Fire-fighting Systems in Buildings is the current British Standard covering the design, installation, testing and maintenance of non-automatic firefighting systems, including private fire hydrants and dry and wet fire mains.
Clause 7.4.4 specifically addresses the maintenance of fire hydrants.
It recommends that owners or occupiers arrange for all private fire hydrants to receive maintenance by a competent person at least once a year.
The standard also recommends periodic inspections to ensure that hydrants remain accessible, their identification plates are present and isolation valves are maintained in their intended positions.
Flow and pressure should also be checked periodically to establish that the available water supply hasn’t deteriorated.
It’s worth distinguishing the annual competent-person maintenance recommendation from the frequency of every individual flow or pressure test. The appropriate testing programme should reflect BS 9990, the system’s design requirements, site circumstances and any applicable additional guidance or contractual requirements.
This is considerably more than simply checking whether there’s a yellow hydrant marker somewhere on the site.
What Should Be Checked During Private Hydrant Maintenance?
An appropriate inspection and testing programme will consider the physical condition, accessibility and operation of the hydrant, together with the performance of the water supply where testing is required.
For an underground hydrant, this may include the hydrant pit, frame, cover, surrounding paving, outlet connection, operating mechanism and any frost protection valve.
The engineer should look for defects such as damaged covers, waterlogged or obstructed pits, corrosion, leakage, seized valves and missing or damaged identification plates.
The system’s isolation valves also need appropriate attention. A hydrant that appears perfectly serviceable may be of little use if a valve supplying it has been inadvertently closed.
Flow and pressure testing provides additional information about the performance of the water supply, helping identify potential deterioration or restrictions.
Testing should be carried out by a competent person using suitable equipment and procedures. Where the system is connected to a water company’s supply, appropriate arrangements may also need to be made with the water undertaker before testing.
For a practical example, Loughborough University’s published private fire hydrant testing guidance provides for annual testing and describes the inspection of hydrant components, pressure and flow measurements, and maintenance records.
The important point is that these are firefighting facilities which may be provided specifically for the premises and for which suitable maintenance arrangements are necessary.
That makes them very different from a public hydrant in the pavement.
What Private Hydrant Documents Should a Fire Risk Assessor Check?
This is where private hydrants become particularly relevant to the fire risk assessment.
If a building or development relies on a private fire hydrant system, the assessor should establish whether suitable maintenance and testing arrangements are in place.
That normally means asking to see the relevant inspection and test records.
For example, if you’re managing an industrial estate with six private hydrants, we’d expect to establish when they were last maintained, whether each hydrant is included in the programme and whether the contractor identified any defects.
It’s not enough to be told that somebody came out last year if there’s no record of what they actually inspected or tested.
Appropriate documentation should identify the hydrants concerned, the date of inspection or testing, the person or organisation undertaking the work and the results.
Where flow and pressure tests have been undertaken, the measured results should be recorded, together with any relevant design criteria or previous results used to assess performance.
Any defects, recommendations and subsequent repairs should also be documented.
What Happens if the Test Records Aren’t Available?
Imagine we’re assessing a warehouse development with several private fire hydrants.
The managing agent tells us that the hydrants are maintained, but nobody can produce an inspection certificate, test results or any evidence of recent maintenance.
That’s a legitimate concern.
It doesn’t automatically prove that the hydrants are defective, but there is insufficient evidence to demonstrate that the intended maintenance arrangements are being followed.
A reasonable fire risk assessment action might be to obtain the existing records or arrange for a competent contractor to inspect and test the private hydrant system as appropriate.
Now imagine the same site has current inspection and testing certificates, but the most recent report identifies one hydrant with a seized valve.
The assessment should consider that defect, the significance of the affected hydrant and whether suitable remedial action has been arranged.
The fire risk assessor isn’t normally expected to carry out the hydraulic testing themselves. Their role is to establish whether appropriate arrangements exist, examine the available evidence and identify significant matters requiring attention.
Where the results raise concerns, a specialist technical assessment may be needed.
This is consistent with the approach described by Bedfordshire Fire and Rescue Service in its guidance on private hydrants, which emphasises regular inspections, operational checks, periodic flow and pressure testing and retention of maintenance records.
The difference is straightforward: with a public hydrant, the building owner isn’t normally responsible for producing maintenance records. With a private hydrant for which they have maintenance responsibility, those records form an important part of demonstrating suitable fire safety management.
What Other Firefighting Facilities Should Your Fire Risk Assessment Consider?
Private hydrants aren’t the only firefighting facilities that may fall within the Responsible Person’s duties.
Article 38 of the Regulatory Reform (Fire Safety) Order 2005 specifically addresses the maintenance of facilities provided for firefighters.
Where necessary for firefighters’ safety, it requires the Responsible Person to ensure that relevant facilities and equipment provided under the Fire Safety Order or other legislation are properly maintained.
These can include installations originally required under the Building Regulations.
Depending on the building, that might include dry or wet rising mains, firefighting lifts, smoke control systems and access arrangements provided for firefighters.
A privately installed facility that doesn’t fall directly within Article 38 may still need maintenance under other applicable duties, the building’s fire safety arrangements, insurance conditions or contractual obligations.
The important consideration is that the facilities necessary for the building’s fire safety strategy remain available and effective.
Dry and Wet Rising Mains
Dry and wet rising mains allow firefighters to obtain water at appropriate locations within a building.
A dry riser is normally supplied through an external inlet by the fire and rescue service, while a wet riser incorporates a water supply arrangement.
These systems need appropriate inspection and maintenance, including relevant testing to BS 9990.
The standard recommends six-monthly inspections of fire-main components, with annual testing appropriate to the type of system.
During a fire risk assessment, we’d expect to consider whether suitable maintenance arrangements exist, whether inspection and test records are available and whether obvious defects could affect the equipment’s operation.
A damaged dry riser inlet, missing outlet cap or inaccessible landing valve could delay firefighting operations.
These are legitimate matters for the fire risk assessment because the equipment is provided for the building and the appropriate dutyholder can arrange for defects to be rectified.
Firefighting Lifts
Some buildings incorporate lifts specifically designed and equipped for use by firefighters.
These form part of the building’s firefighting arrangements and may be particularly important in taller or more complex premises.
Where such a lift is installed, it needs suitable inspection, testing and maintenance.
The fire risk assessment should consider whether those arrangements exist and whether any known defects affect the intended protection.
A lift being operational for normal passenger use doesn’t necessarily demonstrate that all its specialist firefighting functions are operating correctly.
Fire Appliance Access
Access for fire appliances can be equally important.
If a building has a designated appliance route, access gate, turning area or hardstanding, those arrangements need to remain suitable for their intended purpose.
A gate that firefighters cannot open, vehicles blocking an access road or storage containers occupying an appliance turning area could cause significant difficulties during an incident.
Unlike the maintenance of a public water company’s hydrant, these are often matters the building owner or occupier can influence directly.
Where the problem affects the building’s firefighting arrangements, it may be a legitimate fire risk assessment finding.
What About High-Rise Residential Buildings?
For high-rise residential buildings in England, there are additional legal requirements under the Fire Safety (England) Regulations 2022.
These apply specific duties to high-rise residential buildings containing at least two domestic premises and measuring at least 18 metres in height or having at least seven storeys.
Regulation 7 requires the Responsible Person to undertake monthly routine checks of firefighting lifts, evacuation lifts and specified essential firefighting equipment.
This includes equipment such as dry and wet riser inlets and outlets, smoke control systems and other defined systems.
Where relevant equipment is found to be defective, steps must be taken to rectify the problem.
If a fault cannot be rectified within 24 hours of being identified, the Responsible Person must report it electronically to the local fire and rescue authority as soon as reasonably practicable. The authority must also be notified electronically when the defect has been rectified.
Records of the monthly checks must be maintained and made accessible to residents.
The Home Office’s guidance on lifts and essential firefighting equipment explains these additional responsibilities.
Importantly, the monthly checks don’t replace specialist servicing and maintenance.
And they don’t turn the public hydrant in the road into a privately maintained building asset.
The Regulations identify particular equipment that must be checked. They don’t impose a blanket monthly checking obligation on the building owner for public hydrants.
What If the Public Fire Hydrant Is Obstructed?
This is where public hydrants can become relevant to a fire risk assessment, even though the building owner isn’t responsible for maintaining them.
Imagine a restaurant where delivery vehicles regularly stop over the public hydrant outside the premises.
The restaurant doesn’t own the hydrant, but it may have considerable influence over where its suppliers stop.
Similarly, a managing agent might control a private roadway where refuse containers, parked vehicles or contractors’ materials obstruct a hydrant or prevent firefighters from reaching a building.
These are practical issues that may be within the Responsible Person’s control or influence.
In those circumstances, an appropriate action could involve changing delivery arrangements, relocating storage or ensuring that contractors keep access clear.
The distinction is between maintaining the hydrant itself and controlling activities that interfere with its use.
Under Section 42 of the Fire and Rescue Services Act 2004, unauthorised use of fire hydrants and damage or obstruction are subject to specific offences.
However, the fact that an unrelated vehicle occasionally parks over a public hydrant doesn’t automatically make the owner of the neighbouring building responsible for enforcing parking restrictions.
Where the matter is outside the building management’s control, it may be more appropriate to report the concern to the local fire and rescue authority or other relevant organisation.
The FIA specifically highlights the importance of considering how much control or influence the dutyholder has before turning an obstructed public hydrant into a significant fire risk assessment finding.
That’s an important principle in its own right.
Can a Fire Risk Assessor Open or Test a Public Hydrant?
Not simply because they’re undertaking a fire risk assessment.
Public hydrants form part of the water supply infrastructure and should only be operated by people who are appropriately authorised.
A fire risk assessor shouldn’t lift a public hydrant cover, open the valve or attempt to carry out a flow test without the necessary permission and competence.
There are legal considerations.
Section 174 of the Water Industry Act 1991 creates offences involving certain intentional, reckless or negligent interference with water undertakers’ pipes, structures and apparatus without consent.
Section 42 of the Fire and Rescue Services Act also restricts unauthorised hydrant use.
Proper flow and pressure testing requires suitable equipment and procedures, together with appropriate arrangements with the organisations responsible for the water supply.
The existence of a yellow hydrant marker outside the premises doesn’t mean the assessor knows the available water flow, nor does it establish how firefighters would use the hydrant during an emergency.
If a public hydrant appears damaged or defective, the appropriate response is to report the concern to the relevant authority, not attempt to test or repair it personally.
Does the Fire Risk Assessment Need to Establish Hydrant Flow and Pressure?
For an ordinary public hydrant serving the wider area, determining its water flow and pressure isn’t normally a routine part of the neighbouring building’s fire risk assessment.
The Responsible Person doesn’t maintain the public water supply, and the fire risk assessor doesn’t generally have the authority or operational information needed to evaluate it.
The situation is different for a private hydrant system designed specifically to serve a building or development.
Where private hydrants form part of the intended firefighting provision, their performance may need to be checked against the applicable design requirements.
That’s where competent-person testing and documented flow and pressure results become important.
For example, if an industrial estate has a private fire main supplying hydrants around several warehouses, the maintenance arrangements should provide appropriate assurance that the system remains operational and that the supply hasn’t deteriorated.
Where testing identifies inadequate performance, the results may require further investigation and remedial action.
That could involve problems with valves, pipework, the supply arrangement or other components.
A fire risk assessor should consider the significance of those findings, but detailed hydraulic investigations and confirmation of technical performance should be undertaken by an appropriately competent specialist.
There are also circumstances where firefighting water supply needs to be considered during the design of a new building, substantial extension or fire strategy.
Those are different from requiring the owner of an existing shop to obtain a flow test for the public hydrant in the pavement.
Why Has BS 9792:2025 Caused Confusion?
BS 9792:2025 is the British Standard code of practice for fire risk assessments in housing.
It includes recommendations concerning firefighting facilities, including reference to hydrants and the adequacy of water supplies.
The difficulty identified by the FIA is that some of the guidance doesn’t clearly distinguish between public and private hydrants.
In Mythbuster 30, the FIA challenges the suggestion that fire risk assessors should assess the capacity of public hydrants or record public hydrant maintenance deficiencies as actions for the building’s Responsible Person.
The association argues that these matters sit outside the dutyholder’s responsibilities and the normal scope of a fire risk assessment under the Fire Safety Order.
It has raised its concerns formally with BSI.
It’s important to be clear that this is the FIA’s interpretation and criticism of the standard. It isn’t an announcement that BS 9792 has been withdrawn or amended.
The standard remains published, and its recommendations concerning private hydrants, firefighting access and facilities provided for buildings are still relevant.
However, the distinction between public and private infrastructure is essential when deciding whether a particular recommendation creates a meaningful action for the building owner.
The same principle applies more broadly to fire risk assessments.
A competent assessor needs to understand the purpose of the recommendation, the relevant legislation and the extent of the Responsible Person’s control.
Simply including a finding because an item appears in a checklist doesn’t necessarily produce a useful assessment.
Do Older Buildings Have to Upgrade Their Firefighting Facilities?
Not automatically.
The government’s Fire Safety in Purpose-Built Blocks of Flats guidance recognises that existing buildings may have been constructed under different standards from those applying today.
Section 71 explains that, other than in very unusual circumstances, existing blocks of flats shouldn’t generally be required to install or upgrade firefighting facilities that weren’t required under the standards applicable when the building was constructed.
However, facilities that were provided should remain properly maintained and available for use.
That doesn’t mean older buildings are exempt from necessary improvements.
Changes to the premises, significant deficiencies or alterations to the fire safety strategy may justify further assessment or remedial work.
But there is an important distinction between maintaining an existing facility, correcting a genuine defect and upgrading an older building to match every current design recommendation for new construction.
A fire risk assessment should recognise those differences rather than treating them as interchangeable.
Why Does It Matter What Goes Into Your Fire Risk Assessment Action Plan?
A fire risk assessment should provide a practical and proportionate programme for managing fire safety.
That means identifying significant deficiencies, explaining why they matter and recommending actions that the appropriate dutyholder can take.
An action requiring a managing agent to arrange the overdue annual maintenance of a private hydrant system is understandable.
The managing agent can appoint a competent contractor, obtain the inspection and testing records, arrange repairs and demonstrate that the necessary work has been completed.
An action requiring a landlord to repair a damaged dry riser inlet or remove obstructions from a designated fire appliance route is similarly practical.
But what happens when the assessment says the landlord must confirm the flow capacity of the public hydrant in the road?
They contact a maintenance company, which explains that it doesn’t maintain public hydrants.
They contact the water company, which may direct them to the fire and rescue service.
The fire and rescue service may explain that public hydrants are dealt with through established statutory and operational arrangements.
Meanwhile, the action remains outstanding.
When the next fire risk assessment is undertaken, the same unresolved action may be carried forward.
The problem is that nobody has established why the recommendation belongs to the building’s Responsible Person in the first place.
An action plan becomes less useful when it contains obligations that the person receiving it has neither the responsibility nor the authority to fulfil.
This doesn’t mean significant concerns involving third-party infrastructure should simply be ignored.
There may be circumstances where an issue needs to be reported to another organisation, or where different dutyholders need to co-operate to address a wider fire safety problem.
But a fire risk assessment should distinguish between an issue that the Responsible Person must rectify, a concern that needs referring to another organisation and information recorded for context.
That distinction makes the assessment more useful and helps ensure that genuine safety priorities receive the attention they deserve.
What If Your Fire Risk Assessment Already Has an Action About a Fire Hydrant?
Start by establishing whether the hydrant is public or private.
If it’s a public hydrant connected to the water company’s mains, and the action requires you to inspect, maintain or test its capacity, ask the assessor to explain why that responsibility has been allocated to you.
The proximity of the hydrant to your building doesn’t automatically transfer maintenance duties.
If the issue concerns a genuine obstruction caused by activities under your control, that’s different. There may be practical changes you can make to keep the hydrant accessible.
If the concern relates to damage or obstruction outside your control, reporting it to the relevant authority may be the appropriate response.
For a private hydrant system, however, the assessment should establish who is responsible for maintenance and whether the equipment is included in a suitable inspection and testing programme.
That includes reviewing the available records and identifying any overdue maintenance, missing documentation or significant defects.
Where the ownership or maintenance responsibility isn’t clear, establishing it may itself be a legitimate action.
The objective should be to make sure the right organisation is responsible for the right equipment, rather than allowing an unclear recommendation to remain outstanding indefinitely.
So, Should Fire Hydrants Be Included in Your Fire Risk Assessment?
The answer depends on what kind of hydrant you’re dealing with.
For a normal public fire hydrant connected to the water company’s mains, maintenance and testing aren’t ordinarily the responsibility of the neighbouring building’s owner or occupier. The Water Industry Act 1991 and the Fire and Rescue Services Act 2004 establish separate duties and arrangements for public firefighting water supplies.
Where a public hydrant is obstructed by activities under the building management’s control, that may still justify an appropriate action.
But private hydrants are different.
Private hydrants should be subject to regular competent-person maintenance in accordance with BS 9990:2015, including the recommended annual maintenance and appropriate periodic inspections and performance testing.
Where the building’s Responsible Person or another relevant dutyholder is responsible for that equipment, the maintenance and testing records should be available for review during the fire risk assessment.
The same principle applies to dry and wet risers, firefighting lifts, smoke control installations and other firefighting facilities provided for the premises.
At ESI Fire Safety, we believe a useful fire risk assessment should do more than identify potential problems. It should explain what matters, why it matters, who’s responsible and what needs to happen next.
That means recognising the difference between public infrastructure and privately maintained firefighting facilities, while ensuring that genuinely important equipment isn’t overlooked.
Because a longer action plan doesn’t necessarily mean a safer building. What matters is whether the right issues have been identified and the right people are taking the right actions.
Fire Risk Assessments and Fire Safety Consultancy from ESI Fire Safety
At ESI: Fire Safety, we undertake fire risk assessments and provide practical fire safety consultancy for commercial buildings, industrial premises, residential developments and complex or mixed-use properties.
Our work includes assessing firefighting facilities, reviewing maintenance and testing records, identifying significant deficiencies and advising Responsible Persons on their responsibilities under the Regulatory Reform (Fire Safety) Order 2005.
We work throughout Surrey, Hampshire, Berkshire, South West London and the wider South East.
Whether your premises have private fire hydrants, dry or wet risers, firefighting lifts or other specialist firefighting facilities, we can help you establish what needs to be maintained, what evidence should be available and whether the existing arrangements are suitable.
And if your existing fire risk assessment contains unclear recommendations about public hydrants or other equipment outside your control, we can help you understand what the legislation actually requires.
ESI: Fire Safety — No Shortcuts in Safety.
Contact ESI: Fire Safety to discuss your fire risk assessment or the maintenance responsibilities for your building’s firefighting facilities.
This article focuses on legislation and fire safety arrangements in England. The principal provisions of the Fire Safety Order, Water Industry Act and Fire and Rescue Services Act discussed also apply in Wales. The additional duties under the Fire Safety (England) Regulations 2022 apply in England only.
