Navigating fire safety challenges in social housing: a critical examination

By Anthony Walker FRICS FCIOB MIFireE

Press Release version of article by Anthony Walker FRICS FCIOB MIFireE published in Partnerships Bulletin– 14 October 2025

Long-term contracts present various challenges, and ensuring robust fire safety is chief among them. Retrospective Fire Strategies are critical to ensuring enduring compliance, says Sircle director Anthony Walker..

Since the late 1990s, PFI projects have reshaped much of the UK’s public estate. In the years since many of these buildings were designed and constructed, the regulatory landscape has shifted markedly. The Building Safety Act 2022, revised fire safety guidance, and closer regulatory scrutiny have all elevated expectations. This change has created a clear need for Retrospective Fire Strategies (RFS) to ensure assets reflect current risks, operations, and legal duties.

The core challenge is often a gap between the building’s original design intent and how it is used today. Over time, occupancy patterns evolve, spaces are repurposed, and minor alterations accumulate.

Individually modest changes can, in combination, undermine key fire precautions. Compartmentation can be breached, escape routes subtly compromised, and detection or alarm systems become less suited to the building’s live operation – frequently without current duty-holders being fully aware. An RFS provides a structured, proactive means for owners and duty-holders to realign protections with present-day realities, keeping people safe and the building resilient and compliant.

• Missing, incomplete, or outdated fire safety documentation that hinders confident decision-making.
• Shifts in building use, density, or operating hours that alter risk profiles.
• Patchy records of fire safety management, testing, and maintenance regimes.
• Fragmented responsibilities across Special Purpose Vehicles (SPVs), facilities management providers, and public sector clients.
• Design and layout changes following minor works or space rationalisation that cumulatively erode protections.
• Unauthorised alterations to fire doors or ironmongery that deviate from manufacturer’s instructions and certification.

Data and resourcing challenges

For duty-holders and accountable persons, particularly under the Building Safety Act 2022 and the Fire Safety (England) Regulations 2022, these gaps present legal, ethical, and operational risks. Without a robust, current strategy, liabilities increase and regulatory scrutiny intensifies. An RFS closes these gaps by consolidating evidence, clarifying duties, and setting out proportionate actions.

From reactive to proactive

RFSs are sometimes commissioned only after enforcement, insurer queries, or an adverse event. A smarter approach is to get ahead of issues. As many PFI contracts approach expiry and ownership transfers draw nearer, embedding fire safety into structured risk and asset management becomes essential. A proactive RFS helps avoid last-minute surprises, reduces handback disputes, and supports a smoother transition of responsibilities.

What a good RFS involves

A high-quality RFS is forensic yet practical. It does not start from a blank sheet; it interrogates what exists and how the building is actually used. Typically, this includes:

• Reviewing as-built drawings, historic fire risk assessments, O&M records, and maintenance logs to establish the baseline.
• Conducting non-intrusive site inspections with targeted checks on compartmentation, fire-stopping, vertical and horizontal separation, and means of escape.
• Engaging with facilities managers, responsible persons, and end-users to understand operational realities, maintenance constraints, and live risk.
• Analysing divergences between original design intent and current building use, including management arrangements and staffing.
• Providing risk-based, prioritised recommendations for remedial works, system upgrades, management controls, and monitoring arrangements.

The output is a single, authoritative control document that clarifies responsibilities and strengthens safety culture. It informs future fire risk assessments, dovetails with planned works, and supports assurance reporting to boards, funders, and regulators.

Commercial and contractual benefits

Commissioning a retrospective fire strategy delivers tangible value for PFI stakeholders:

• Strengthens the building’s safety narrative with a clear evidence trail.
• Reduces liability exposure at lease handback by addressing issues early and transparently.
• Supports planned refurbishments or changes of use with focussed, risk-based guidance.
• Increases confidence among insurers, regulators, occupants, and incoming owners.
• Demonstrates proactive stewardship, improving relationships and smoothing approvals.

For public bodies, an RFS provides assurance that contractual obligations are being met and legacy risks are being actively managed. For SPVs and FM providers, it creates clarity around roles, responsibilities, and costed action plans, reducing dispute potential and programme risk.

RFS as a living document

An RFS should not be produced and then left on a shelf. It needs to operate as a live reference for day-to-day decisions, inductions, training, and evacuation procedures, as well as for planning permissions, building control submissions, and future alterations. Regular review points keep it aligned to the building’s evolving use and the latest guidance. When operations change, the strategy should be refreshed so the management system stays in step with reality.

Governance, roles, and assurance

Clarity on governance is critical. The RFS should set out who does what, by when, and how performance is monitored. Clear escalation routes, change controls for alterations, and evidence logs for inspections and testing all improve auditability. Periodic assurance checks, internal or third-party, keep focus on outcomes and maintain confidence with boards and regulators. Where responsibilities are shared between SPVs, FM providers, and public clients, the RFS should define interfaces and remove ambiguity. 

A Fire Risk Assessment (FRA) should take place following each RFS, and align with a clear responsibility matrix identifying which of the parties owes the relevant duty. This is a key governance protocol to ensure statutory compliance and one the relevant fire authorities will look out for when there is an incident that requires an investigation to be carried out, or where they want to issue an enforcement notice.

Handback and future-proofing

With many PFI assets moving towards contract expiry, an RFS supports a clean handback. It evidences how risks have been managed, what remedial works have been completed, and what residual risks remain. It also helps future owners understand the building’s protection strategy, which reduces uncertainty, expedites onboarding, and protects continuity of operations.

Conclusion: reassess, revalidate, and reassure

RFS for PFI and PPP buildings sit at the intersection of historical design intent, contemporary regulation, and forward-looking asset management. By adopting a proactive, collaborative approach, duty-holders can align real-world operation with the Building Safety Act 2022 and related guidance, while unlocking commercial, operational, and community confidence benefits. 

Investment in a thorough RFS demonstrates a visible commitment to life safety and professional stewardship. With regular review and smart digital integration, the strategy remains genuinely ‘live’ – evolving with the building, guiding practical decisions, and turning fire safety from a narrow compliance obligation into a core component of long-term, value-driven asset management.