Fire Risk Assessments for Schools

A school needs a fire risk assessment because it is non-domestic premises and a workplace: the Fire Safety Order applies, and the responsible person must assess the risk to everyone who may be on site. Since 1 October 2023 that assessment, and the fire safety arrangements built on it, must be recorded in full in all circumstances.

What makes schools genuinely different from a comparable office is not the law — it is the population and the rhythm. A large number of occupants, many of them children, some needing evacuation assistance, moving between rooms on a timetable, in premises that frequently mix a Victorian block with a 1970s extension and a modular classroom, and which get altered every summer holiday. This guide covers the ground a school assessment has to cover, who owes the duty across different school types, and the two places the government guidance splits in a way that catches people out.

This article summarises UK fire safety law for educational purposes and is not legal advice. The responsible person carries the legal liability for fire safety in the premises. For specific compliance questions, consult a competent fire risk assessor or your local fire and rescue authority.

Who the Responsible Person Is

Under Article 3 of the Regulatory Reform (Fire Safety) Order 2005, the responsible person is:

"in relation to a workplace, the employer, if the workplace is to any extent under his control"

So in a school the question becomes: who is the employer? That depends on the school type, and it is worth being precise because the answer is not uniform. GOV.UK health and safety guidance for schools puts the general position this way:

"The employer or, in the case of independent schools, the proprietor, is accountable for the health and safety of school staff and pupils."

That guidance separates out independent schools explicitly, and notes that local authorities hold specific powers under the Education Act 2002 in relation to "community schools, voluntary controlled schools, community special schools, maintained nursery schools, pupil referral units" — powers it says should be exercised only where a school's own arrangements are inadequate.

What it does not do is hand you a clean employer-by-school-type table, and you should be wary of any source that claims to. The reliable route is to apply the Article 3 test to the actual arrangement: identify the employer of the staff, and check the extent to which the premises are under their control. In a multi-use site — a school sharing a building with a nursery, a leisure centre or a community trust — there may be more than one responsible person, with a duty on each to cooperate. Our guide to who is responsible for a fire risk assessment works through the allocation test in full.

Delegation is normal and fine: a head teacher, business manager or estates lead usually runs the work. It does not move the liability.

The Guidance That Actually Applies — and the Split That Catches People

Two government documents get confused here, and they do completely different jobs.

Fire safety risk assessment: educational premises is the assessment guide. It is written for:

"employers, head teachers, governors, vice-chancellors, occupiers and owners of premises where the main use of the building (or part of the building) is for educational purposes"

and covers schools, universities, academies, crèches, adult education centres, outdoor education centres and music schools.

Building Bulletin 100 (Design for fire safety in schools) is something else entirely. GOV.UK describes it as "a design guide for fire safety in schools" — DfE design guidance aimed at designers, fire engineers and building control, about how school buildings are built and refurbished. It is still listed in the GOV.UK design guidance building bulletins collection and remains a useful design reference — but a design guide is not a fire risk assessment methodology, and citing it as one is a category error. Your assessment duty comes from the Fire Safety Order.

The split that catches people: the educational premises guide explicitly excludes residential premises such as university halls of residence and boarding school sleeping accommodation. Sleeping risk changes detection expectations, escape strategy and management arrangements, so those areas are dealt with under the sleeping accommodation guidance instead.

The practical consequence: a boarding school needs both. An assessment that covers the teaching blocks well and treats the boarding house as just another wing has used the wrong frame of reference for the highest-risk part of the site. The same applies to a residential outdoor education centre, and to a day school that hosts occasional residential stays — if people sleep on site, even sometimes, that has to be assessed as sleeping accommodation.

What a School Assessment Has to Cover

The subject matter below is the ground to work through. Depth varies enormously between a single-block primary and a split-site secondary with a sixth form, a sports centre and a boarding house.

People

• Numbers and distribution across the site by time of day, including the peak — usually a whole-school assembly or a lunch sitting.
• Pupils and staff needing evacuation assistance, whether for mobility, sensory, cognitive or medical reasons, permanently or temporarily (a broken ankle changes someone's escape route for six weeks). Each needs an individual plan, not a line in the general procedure.
• Very young children, who will not self-evacuate reliably and need staff-led movement — a materially different assumption from an office.
• Visitors, contractors and parents, including at events like parents' evenings and performances when occupancy patterns are completely unlike a school day.
• Lettings and out-of-hours users. Community groups, sports clubs and holiday schemes may use parts of the site with none of the school's staff present. Who is the responsible person during a letting, and does the hirer know the procedure?

The premises

• Mixed construction and phased extensions, and whether compartmentation actually holds where an old block meets a newer one — a very common weak point.
• Escape routes and travel distances, including from upper floors, mezzanines and temporary or modular classrooms.
• Final exits and external routes, including whether gates on the escape route are secured against intruders in a way that also obstructs escape. This is a genuine and recurring tension in schools between safeguarding and fire safety, and the assessment should name it rather than ignore it.
• The assembly point and whether it is usable in winter, clear of the fire service approach, and large enough for the whole school.

Higher-risk areas

Schools concentrate hazards in identifiable places, and these deserve specific attention rather than a general observation:

• Science laboratories and prep rooms — flammable and reactive chemical storage, gas taps, quantities held.
• Design and technology workshops — hot works, dust extraction, machinery, finishes and solvents.
• Art and ceramics — kilns, solvents, accumulation of combustible materials.
• Kitchens and catering — cooking appliances, extraction ductwork cleaning, and whether the ductwork is on a maintenance regime at all.
• Boiler and plant rooms, server rooms, and storage — including the cupboard that has quietly become a store for stacked chairs and cardboard.
• Drama and performance spaces — temporary staging, drapes, seating layouts and pyrotechnic or smoke-effect use.

Management and systems

• Detection and alarm appropriate to the premises and its occupancy, and whether the coverage still matches a site that has been extended since the system went in.
• Emergency lighting on escape routes, including external routes.
• Fire doors and whether they are held open by wedges, extinguishers or a stack of exercise books — endemic in corridors and worth recording honestly.
• Drills, including at least one in conditions that are not ideal, and records of how long evacuation took.
• Staff training, including new and supply staff who may not know the routes.
• Arson risk — external bin storage, site perimeter, out-of-hours access. Schools are a recognised arson target and this is often the single most under-assessed item.
• Contractor control, especially during holiday works, which is when both the risk and the disruption to normal arrangements peak.

That last point deserves emphasis. The riskiest weeks in a school year for fire safety are usually the ones with no pupils in the building: hot works underway, escape routes obstructed, alarm zones isolated, compartmentation opened up, and the normal management routine suspended. If an assessment says nothing about how holiday works are controlled, it has missed the period when something is most likely to go wrong.

Recording, Reviewing and the Academic-Year Rhythm

The recording position is no longer discretionary. Under section 156 of the Building Safety Act 2022, GOV.UK guidance states:

"You must now record the fire risk assessment in full (including all the findings) and the fire safety arrangements for your premises in all circumstances."

Article 9(3) requires review:

"regularly so as to keep it up to date and particularly if— (a) there is reason to suspect that it is no longer valid; or (b) there has been a significant change ..."

In a school the significant changes arrive on a schedule, which is genuinely useful — you can anticipate them. Summer building works. A new modular classroom. A changed intake including pupils needing evacuation assistance. A new catering contractor or a change to DT provision. A reorganisation that moves year groups between floors. Reviewing in the run-up to the new academic year, and again after any summer works complete, matches the review duty to the way the premises actually changes.

Our guide to how often a fire risk assessment should be reviewed covers the trigger events in general, and the free FRA review date calculator will set a date from the last assessment. For the on-site ground, our 30-point fire risk assessment checklist is a general working list to adapt, and anyone who cannot evacuate unaided needs the individual planning covered in our guide to PEEPs and who needs one.

Commissioning an Assessment

Schools are not simple premises, and a generic assessment shows. When appointing an assessor, ask specifically about education experience: mixed-age occupancy, laboratory and workshop risk, lettings, and boarding accommodation if you have it. Article 18(1) of the Order requires the responsible person to "appoint one or more competent persons to assist him in undertaking the preventive and protective measures" — expressly "subject to paragraphs (6) and (7)", which release a responsible person who has the training, experience and knowledge to undertake those measures personally. So it is not an unqualified duty to hire someone; where you do commission, the judgement of competence sits with you — our guide to how to choose a fire risk assessor sets out what to check, and the fire risk assessment cost guide gives realistic fee ranges by building type.

Summary

Schools sit squarely inside the Fire Safety Order: assess the risk to everyone on site, record it in full, and review it when things change. The specifics that separate a good school assessment from a generic one are the population (young children, pupils needing assistance, visitors at events, out-of-hours hirers), the premises (phased construction, compartmentation at the joins, secured gates on escape routes), the concentrated hazards (labs, workshops, kitchens, kilns, plant), and the holiday works period when normal arrangements are suspended.

Get two things right that are commonly got wrong. Building Bulletin 100 is design guidance, not an assessment methodology. And if anyone sleeps on the site — boarders, residential visits — the sleeping accommodation guidance applies to those areas, because the educational premises guide expressly excludes them.

For assessors covering education portfolios, AssessKit structures every assessment to a recognised methodology (PAS 79-1 for non-domestic premises, BS 9792:2025 for housing), tracks remedial actions through to completion, and holds review dates per site so an academic-year review cycle across a multi-site trust does not depend on memory. Start free — the Free plan covers two assessments a month, no card required. See pricing or read about who is building it.

Sources

• Regulatory Reform (Fire Safety) Order 2005 (legislation.gov.uk)
• Article 3 — Meaning of "responsible person" (legislation.gov.uk)
• Article 9 — Risk assessment (legislation.gov.uk)
• Fire safety risk assessment: educational premises (GOV.UK)
• Fire safety risk assessment: sleeping accommodation (GOV.UK)
• Health and safety: responsibilities and duties for schools (GOV.UK)
• Design guidance: building bulletins — including BB100 (GOV.UK)
• Fire safety responsibilities under section 156 of the Building Safety Act 2022 (GOV.UK)