The Regulatory Reform (Fire Safety) Order 2005 (RRO)
The Regulatory Reform (Fire Safety) Order 2005 (RRO) does not explicitly use the term “passive fire protection” in its text, but it mandates several fire safety measures that directly involve PFP systems, such as fire-resistant structures, compartmentation, and fire doors, as part of the general fire precautions required for non-domestic premises in England and Wales. Below, I’ve outlined the key provisions from the RRO that implicitly or explicitly relate to PFP, based on the legislation itself and supporting guidance from the provided web sources. The RRO, effective from October 1, 2006, consolidated previous fire safety laws and emphasizes a risk-based approach, requiring Responsible Persons (RPs) to ensure fire safety through measures that include PFP components.
Key Provisions of the RRO Related to Passive Fire Protection
Article 4 – General Fire Precautions
- Text: Defines “general fire precautions” to include measures to reduce the risk of fire and its spread on the premises, measures ensuring safe means of escape, and maintaining these precautions.
This includes structural fire resistance (e.g., fire-resistant walls, floors, and ceilings), compartmentation to limit fire spread, and fire doors to protect escape routes. These are core PFP elements designed to contain fires and ensure safe evacuation without reliance on active systems like sprinklers.
Article 8 – Duty to Take General Fire Precautions
Requires the RP to take general fire precautions to ensure, as far as reasonably practicable, the safety of employees and non-employees on the premises.
- This duty mandates the installation and maintenance of PFP measures, such as fire-resistant partitions and doors, to reduce fire spread and protect occupants, as these are critical to ensuring premises safety.
Article 9 – Risk Assessment
Mandates that the RP conduct a suitable and sufficient fire risk assessment to identify fire hazards and necessary precautions, with a written assessment required if five or more people are employed (amended in 2023 to require written assessments for all premises, regardless of size).
- The risk assessment must consider PFP elements like fire-resistant structures and escape routes. For example, assessing whether fire doors and compartment walls meet required fire-resistance standards is a key part of compliance.
Article 11 – Fire Safety Arrangements
Requires the RP to make and implement appropriate arrangements for planning, organizing, controlling, monitoring, and reviewing preventive and protective measures, with records required for all premises as of October 2023.
PFP Relevance: This includes maintaining PFP systems, such as ensuring fire doors are functional and fire-stopping materials (e.g., intumescent seals) are intact, as part of the fire safety action plan.
Article 13 – Fire-Fighting and Fire Detection
Requires the RP to ensure premises are equipped with appropriate fire-fighting equipment and, where necessary, fire detectors, maintained in efficient working order.
PFP Relevance: While primarily focused on active systems, this article complements PFP by requiring maintenance of fire safety systems, including ensuring PFP measures like fire doors and compartmentation work in tandem with active systems to enhance overall safety.
Article 14 – Emergency Routes and Exits
Text: Mandates that emergency routes and exits be kept clear, lead to a place of safety, and be adequately signed, with sufficient intensity in case of lighting failure.
PFP Relevance: PFP is critical here, as fire-resistant escape routes (e.g., protected corridors with fire doors and walls rated for fire resistance) are essential to ensure safe evacuation, a cornerstone of PFP design.
Article 17 – Maintenance
Requires that all fire safety facilities, equipment, and devices (including those for firefighters) be maintained in an efficient state, in good repair, and subject to a suitable maintenance system.
PFP Relevance: This explicitly includes PFP components like fire doors, fire-resistant walls, and fire-stopping systems (e.g., intumescent sealants for penetrations), which must be regularly inspected and maintained to ensure they function as intended during a fire.
Article 21(a) – Provision of Information to Residents (Added via Section 156 of the Building Safety Act 2022)
Requires RPs in buildings with two or more domestic premises to provide residents with comprehensible information about relevant fire safety matters, including fire doors.
PFP Relevance: Specifically mentions fire doors, a key PFP component, emphasizing their role in protecting residents in multi-occupied residential buildings and the need to inform residents about their importance.
Article 38 – Maintenance of Measures for Firefighters
Requires measures provided for the protection of firefighters (e.g., fire-fighting shafts, dry/wet risers) to be maintained in good condition.
PFP Relevance: Fire-fighting shafts and protected stairways often rely on PFP, such as fire-resistant walls and doors, to ensure firefighters can access and operate safely within a building during a fire.
Government Guidance: The RRO is supported by 16 guidance documents, including a 5-step checklist and 12 premises-specific guides (e.g., for offices, shops, factories, and residential buildings), which detail PFP measures like fire-resistant compartmentation, fire doors, and fire-stopping systems. These guides, available on gov.uk, emphasize that PFP is integral to compliance, particularly for maintaining escape routes and limiting fire spread.
Fire Safety Act 2021 Clarification: The Fire Safety Act 2021, amending the RRO, clarified that external walls, flat entrance doors, and building structures in multi-occupied residential buildings are covered by the RRO, explicitly including PFP elements like fire-resistant doors and walls.
Practical PFP Measures: Guidance documents highlight specific PFP requirements, such as:
Fire Doors: Must be installed and maintained to provide fire resistance (e.g., 30 or 60 minutes) and protect escape routes.
Compartmentation: Fire-resistant walls and floors to prevent fire spread between sections of a building.
Fire-Stopping: Intumescent materials to seal penetrations (e.g., pipes, cables) through fire-resistant barriers.
The RRO does not use the term “passive fire protection” explicitly but embeds PFP within its requirements for general fire precautions, risk assessments, and maintenance. The focus is on practical measures like fire-resistant structures, doors, and compartmentation.
The amendments introduced by Section 156 of the Building Safety Act 2022 (effective October 2023) strengthened PFP requirements, particularly for fire doors in residential buildings and documentation of PFP measures in all premises.
Article 4 – General Fire Precautions
Defines general fire precautions as measures to reduce the risk of fire and its spread, ensure means of escape, and maintain these measures.
- Compartmentation Relevance: Compartmentation, achieved through fire-resistant walls, floors, and ceilings, is a primary method to limit fire spread and protect escape routes, ensuring occupants can evacuate safely.
Article 8 – Duty to Take General Fire Precautions
- Text: Requires the RP to ensure, as far as reasonably practicable, the safety of employees and non-employees from fire risks.
- Compartmentation Relevance: This includes installing and maintaining fire-resistant compartments to contain fires, protecting occupants and property.
Article 14 – Emergency Routes and Exits
- Text: Mandates that emergency routes and exits remain clear, lead to a place of safety, and are adequately protected.
- Compartmentation Relevance: Compartmentation ensures escape routes (e.g., corridors, stairwells) are protected by fire-resistant barriers, maintaining their integrity during a fire.
Article 17 – Maintenance
Requires fire safety facilities, including those for limiting fire spread, to be maintained in an efficient state and good repair.
- Compartmentation Relevance: Fire-resistant walls, floors, and fire-stopping systems (e.g., for penetrations) must be regularly inspected to ensure they meet fire-resistance standards.
Article 38 – Maintenance of Measures for Firefighters
Requires measures for firefighters (e.g., fire-fighting shafts) to be maintained.
- Compartmentation Relevance: Fire-fighting shafts and protected stairways rely on compartmentation to remain accessible, using fire-resistant walls and doors.
- Fire-Resistance Ratings (Approved Document B, Section 7)
- Standard: Compartmentation elements (walls, floors, ceilings) must achieve a specified fire-resistance duration, typically 30, 60, or 120 minutes, depending on building use, height, and occupancy.
- Details:
- 30 minutes: Common for low-risk, single-storey buildings (e.g., small offices).
- 60 minutes: Required for most non-domestic premises (e.g., shops, factories) and multi-storey buildings up to 18 meters.
- 120 minutes: Mandatory for high-risk or high-rise buildings (e.g., hospitals, buildings over 18 meters).
- Source: ADB Volume 2, Section 7.2, and BS 476-22 (fire-resistance testing).
- Compartment Walls and Floors (ADB, Section 8)
- Standard: Compartment walls and floors must be constructed to prevent fire spread between compartments, with fire-resistance tested to BS 476-20/22 or EN 13501-2.
- Details:
- Walls must extend from floor to ceiling (or roof) and be imperforate except for permitted penetrations (e.g., fire-stopped pipes).
- Floors must resist fire from below or above, typically using materials like reinforced concrete or fire-rated plasterboard.
- Junctions between walls and floors must be sealed to maintain integrity.
- Source: ADB Volume 2, Sections 8.2–8.5.
- Protected Shafts and Stairways (ADB, Section 9)
- Standard: Stairways and service shafts (e.g., for lifts, pipes) must be enclosed in fire-resistant compartments to protect escape routes and prevent vertical fire spread.
- Details:
- Minimum 60-minute fire resistance for stairways in buildings over 11 meters.
- Fire-resistant glazing or shutters for any openings, tested to BS EN 1634-1.
- Self-closing fire doors (FD30S or FD60S) at shaft entrances.
- Source: ADB Volume 2, Section 9.2–9.4.
- Fire-Stopping for Penetrations (ADB, Section 10)
- Standard: Penetrations through compartment walls/floors (e.g., for cables, pipes, ducts) must be sealed with fire-stopping materials to maintain the compartment’s fire resistance.
- Details:
- Intumescent sealants, fire-resistant collars, or pillows must be used, tested to BS EN 1366-3.
- Fire-stopping must match the fire-resistance rating of the wall/floor (e.g., 60 minutes).
- Regular inspections are required to ensure seals remain intact.
- Source: ADB Volume 2, Section 10.3.
- Cavity Barriers (ADB, Section 9)
- Standard: Cavity barriers must be installed in concealed spaces (e.g., suspended ceilings, roof voids) to subdivide cavities and prevent hidden fire spread.
- Details:
- Barriers must provide at least 30 minutes fire resistance (integrity and insulation).
- Maximum cavity spacing: 20 meters in non-residential buildings.
- Materials include mineral wool, intumescent boards, or fire-rated plasterboard, tested to BS 476-20.
- Source: ADB Volume 2, Section 9.10–9.13.
- BS 9999:2017 – Fire Safety in the Design, Management, and Use of Buildings
- Standard: Provides a risk-based approach to compartmentation, tailoring fire-resistance requirements to building use and risk profile.
- Details:
- High-risk premises (e.g., chemical stores) may require 120-minute compartmentation.
- Lower-risk premises (e.g., offices) may use 30–60-minute ratings.
- Emphasizes compartmentation to support phased evacuation in complex buildings.
- Source: BS 9999:2017, Section 19.
- BS 9991:2015 – Fire Safety in Residential Buildings
- Standard: For mixed-use or multi-occupied residential buildings, compartmentation must protect common areas and individual flats.
- Details:
- Flat entrance doors must be FD30S (30-minute fire resistance with smoke seals).
- Common corridors and stairwells require 60-minute fire-resistant walls.
- Lobbies in buildings over 11 meters must be fire-separated from accommodation areas.
- Source: BS 9991:2015, Section 5.
- Fire Safety Act 2021: Clarifies that external walls and flat entrance doors in multi-occupied residential buildings fall under the RRO, requiring compartmentation to prevent fire spread across facades or between flats. In 2024, 20% of enforcement notices targeted such buildings, often citing inadequate compartmentation.
- Audits and Enforcement: In 2024, 49,835 fire safety audits were conducted, with 2,823 formal notifications and 1,671 enforcement notices issued, many addressing compartmentation issues like unsealed penetrations or substandard fire walls.
- Industry Practices: Companies like LDD Construction and Novus Property Solutions, highlighted in 2024 for PFP projects, implemented compartmentation in high-risk facilities (e.g., data centers, social housing) using BS-compliant materials like intumescent coatings and fire-rated plasterboard.
- Training and Compliance: The ASFP PFP Awards 2024 recognized training programs ensuring installers understand compartmentation standards, such as proper installation of fire-stopping systems.
- The RRO itself is high-level, relying on Approved Document B and British Standards (e.g., BS 476, BS EN 13501) for technical compartmentation standards.
- Guidance documents on gov.uk (e.g., for offices, shops, factories) emphasize compartmentation as a legal requirement under the RRO, with specific references to ADB.
- Fire-resistance ratings are tested under BS 476 (Parts 20–22) or European standards (BS EN 13501, BS EN 1634), ensuring consistency across UK buildings.
- For a full text of the RRO, visit www.legislation.gov.uk. Additional guidance is available at www.gov.uk and firesafe.org.uk.
