Fire Risk Assessments for Hotels and Pubs

Hospitality premises combine three things that rarely occur together elsewhere: people asleep, occupants who have never been in the building before and cannot be trained, and a business that runs hardest at night on its thinnest staffing.

That combination — not the building fabric — is what makes a hotel or pub assessment different from an office one. An office assessment can lean on trained occupants who know the routes. A hospitality assessment cannot lean on the occupants at all.

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.

The Duty, and What Triggers It

A hotel, pub, restaurant, guest house or holiday complex is non-domestic premises used in connection with a business, so the Regulatory Reform (Fire Safety) Order 2005 applies. Article 9(1):

"The responsible person must make a suitable and sufficient assessment of the risks to which relevant persons are exposed"

Two definitions do a lot of work in hospitality.

"Responsible person" — under Article 3, in a workplace it is the employer where the workplace is to any extent under their control, and otherwise the person who has control of the premises in connection with the carrying on of a trade, business or other undertaking. In a tenanted pub that can be a genuinely contested question between the operating company and the tenant — worth settling in writing before an incident rather than after. Our guide to who is responsible for a fire risk assessment works through how the Order allocates the duty.

"Relevant persons" — under Article 2, any person lawfully on the premises or in the immediate vicinity who is at risk from fire. In a hotel that is overwhelmingly people you have no relationship with beyond tonight.

Note what does not trigger the duty: sleeping accommodation. The Order applies to the pub with no letting rooms exactly as it applies to the hotel. Sleeping risk changes what the assessment has to solve, not whether one is required.

And on recording: since 1 October 2023, section 156 of the Building Safety Act 2022 means the assessment and the fire safety arrangements must be recorded in full in all circumstances. If a hospitality operator is working from guidance that mentions five or more employees, that guidance predates the change.

Which GOV.UK Guide Applies

The relevant Article 50 guide is Fire safety risk assessment: sleeping accommodation. Its scope, in GOV.UK's own words, covers:

"bed and breakfasts, guest houses, holiday chalets, holiday flat complexes, camping, caravan and holiday parks (other than privately owned individual units)"

and

"areas in work places where staff 'sleeping in' is a condition of the employment or a business requirement as in licensed premises or hotels"

and

"the common areas of houses in multiple occupation"

That second limb is the one pubs miss. A pub where the manager lives above the bar has staff sleeping accommodation whether or not it lets rooms to the public, and the guide reaches it. The third limb — common areas of HMOs — matters for a different reason; see our guide to fire risk assessments for HMOs for how the common-parts duty there interacts with this guide.

The guide expressly does not cover domestic premises, hospitals, residential care and nursing homes, or prisons and other establishments where people are in lawful custody. Care homes have their own regime and a different evacuation problem — see fire risk assessments for care homes.

GOV.UK also publishes a separate, more proportionate guide, Making your small paying guest accommodation safe from fire, for owners of bed and breakfasts, guest houses and self-catering properties. For small unstaffed premises that is usually the better fit — the boundary is worked through in our guide to holiday let fire risk assessments, where the unstaffed self-catering case is the whole subject.

What the Assessment Has to Solve

People are asleep

Sleeping occupants cannot self-rescue on the same assumptions as waking ones. Detection has to reach them in the room they are asleep in, and the escape strategy cannot depend on anyone noticing smoke.

This is also where scope discipline matters. Detection design standards for sleeping risk sit in published British Standards which are not freely available, so the honest position in an assessment is to record what is installed, whether it covers the sleeping accommodation, whether it is maintained, and — where the design standard is in doubt — to recommend that a competent fire alarm engineer confirms the system against the applicable standard, rather than asserting a grade from memory.

Guests cannot be trained

Everything a workplace achieves through training under Article 21 has to be achieved in hospitality through the building and the staff. Practically, the assessment should look hard at:

• Signage and lighting on the route from the room. A guest woken at 3am, disoriented, in an unfamiliar corridor, is the design case.
• Room notices. Whether the instruction in the room actually matches the building's strategy.
• Final exits that open without a key. Night security arrangements are a common source of conflict with this, and locking up is exactly when it gets got wrong.
• Alcohol. In licensed premises this is not a moral observation, it is a design input: impaired occupants respond more slowly and follow instruction less reliably.

The building runs at night on reduced staffing

The assessment has to work against the smallest crew on the rota. A procedure that assumes a duty manager, a receptionist and two floor staff is not a procedure if the 4am reality is one night porter.

Article 15(1) requires the responsible person to:

"establish and, where necessary, give effect to appropriate procedures, including safety drills"

and to nominate a sufficient number of competent persons to implement the evacuation procedures. "Sufficient" is measured against the actual staffing at the time of the risk, not the headcount on the payroll.

Kitchens and plant

Commercial kitchens carry the concentrated ignition and fuel risk in most hospitality premises: cooking equipment, extract ductwork and grease accumulation, and deep fat frying. Ductwork cleaning frequency and the condition of suppression where fitted are among the more commonly deferred items and among the more commonly cited after a loss.

Drills, Training and Turnover

Hospitality's staffing pattern is the reason the training duty behaves differently here.

Article 21 requires employees to be provided with adequate safety training, "repeated periodically where appropriate" and "provided in a manner appropriate to the risk identified by the risk assessment". Neither the Order nor the guide sets a number, which means the interval has to be justified rather than inherited.

In a sector where a substantial share of the team may have joined since the last drill, an annual cycle can leave a majority of the night staff untrained. The more defensible arrangement ties induction fire training to starting rather than to the next scheduled drill, and records attendance by name so the gap is visible. A drill log that says "annual drill completed" without a list of who took part cannot evidence anything about the people actually on shift tonight.

Reviewing It

Hospitality premises change more than their fabric suggests: layouts get reconfigured for events, outdoor areas get covered and heated, kitchens get re-equipped, and letting rooms change use. Article 9(3) requires review regularly and particularly where there is reason to suspect the assessment is no longer valid or there has been a significant change — and in this sector a refurbishment or a change in the sleeping-accommodation footprint is exactly that.

The free FRA review date calculator will set a review date by building type and risk level, and the 30-point fire risk assessment checklist covers the on-site ground.

Summary

The Fire Safety Order applies to hotels and pubs because of the business use, not because anyone sleeps there — but sleeping risk is what the assessment has to solve. The Article 50 guide is Fire safety risk assessment: sleeping accommodation, and its scope expressly reaches licensed premises and hotels where staff sleeping in is a condition of employment, which catches pubs that assume they are out of scope.

Three things distinguish the assessment: occupants are asleep, guests cannot be trained so the building and the staff have to carry it, and the premises run at night on the thinnest staffing on the rota. Test the procedures against that night crew. Tie fire training to induction rather than to the next scheduled drill, and record attendance by name.

For assessors carrying hospitality portfolios, AssessKit keeps each site's findings, remedial actions and review dates together so a multi-site operator's estate does not drift out of cycle. 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 2 — Interpretation, including "relevant persons" (legislation.gov.uk)
• Article 3 — Meaning of "responsible person" (legislation.gov.uk)
• Article 9 — Risk assessment (legislation.gov.uk)
• Article 15 — Procedures for serious and imminent danger and for danger areas (legislation.gov.uk)
• Article 21 — Training (legislation.gov.uk)
• Fire safety risk assessment: sleeping accommodation — Article 50 guidance (GOV.UK)
• Making your small paying guest accommodation safe from fire (GOV.UK)
• Fire safety responsibilities under section 156 of the Building Safety Act 2022 (GOV.UK)