Does Your Property Have a Retrospective Fire Strategy?

So, what actually is it?

An RFS is a formal, building-specific document that sets out how life safety from fire is achieved in an existing building – it looks at what is actually there, rather than what was originally planned. 

Unlike a design fire strategy (written at the planning stage, based on drawings and assumptions), an RFS works from reality. It looks at how the building exists today: how it is used, what has changed over the years, and whether the fire safety measures still add up. 

It is not about imposing today’s standards retrospectively on an older building. It is about demonstrating that the building provides an acceptable level of life safety, considering when it was built, how it is occupied, and what measures are in place. 

When is a RFS required?

You should consider commissioning a RFS if any of the following apply:

• The original fire strategy is missing or can't be found. This is not uncommon, especially in older blocks or those that have changed hands.

• The building has been altered, extended, or converted. Every significant change potentially alters the fire safety position, and someone needs to formally review the cumulative effect.

• The current fire risk assessment identifies uncertainties. If your FRA says "assumptions made regarding compartmentation" or flags issues the assessor couldn't fully resolve, an RFS is the right next step.

• Your lender, insurer or regulator has asked for it. Mortgage lenders and building insurers may require documented evidence of fire safety design intent - not just an FRA.

• You manage a higher-risk building. Under the Building Safety Act 2022, any block of 18 metres or seven storeys or more carries stringent documentation requirements

Why does it matter?

Original paperwork can get lost, buildings get altered without updating the fire strategy. Over time, small changes accumulate; together, they can undermine the protection that residents depend on. 

The Building Safety Act 2022 raised the bar for all residential blocks, not just high-rises. The Fire Safety Act 2021clarified that the Responsible Person’s duties extend to the structure, external walls, and flat entrance doors – not just the common parts, and the Fire Safety (England) Regulations 2022 introduced new requirements around fire doors, resident information, and documentation. 

How is it different from an FRA?

FRAs focus on day-to-day hazards. They provide a live operational check of how fire safety is being managed right now. 

An RFS defines the technical design intent – how the building is supposed to protect people, what the compartmentation strategy is, what evacuation approach is intended, and how the detection and alarm system work in relation to the layout. 

You need both. The RFS sets the blueprint; the FRA checks it is being delivered. 

What does the process actually look like?

A well-run RFS follows a structured process:

1. Evidence gathering. All available documentation is reviewed: as-built drawings, O&M manuals, historic FRAs, maintenance records, and any building control records. A register is compiled of what exists and, crucially, what is missing. 

2. Site inspection. A thorough non-intrusive survey is carried out, with targeted checks on escape routes, compartment walls and floors, fire-stopping at service penetrations, fire doors and ironmongery, emergency lighting, detection coverage, and signage. 

3. Triangulation. Where information is incomplete, sources are cross-checked: surveys, drawings, FRA findings, and historic standards. No single document is relied upon in isolation. 

4. Analysis and justification. The building is assessed against the standards that applied when it was designed, as well as current guidance. Where there are gaps or deviations, the strategy explains whether they are acceptable, what the risk implications are, and what needs to be done. 

5. A prioritised action plan. The output provides an actionable roadmap, with realistic timescales, and responsibilities

What might it find?

Common issues uncovered by RFSs in residential properties include:

• Missing or poorly installed fire stopping around service penetrations and at compartment boundaries

• No up-to-date floor plans with compartmentation line mark up

• Compartment lines compromised by cabling, ductwork or reconfiguration carried out over the years

• Non-compliant fire doors - wrong ironmongery, damaged frames, incorrect gaps, unsealed frames

• Conversions that have created inner rooms or dead-end corridors without adequate detection

• Smoke control logic that no longer matches how the building is configured or managed

• Management gaps - evacuation strategies that exist on paper but don't reflect how the building actually operates.

The above is not an exhaustive list, nor necessarily the fault of the current management. They may pre-date current ownership or management arrangements entirely. The point is to find them, document them, and fix the most important ones systematically.

The Golden Thread 

A RFS is a core part of the golden thread - having accurate, up-to-date information about your building, stored in a way that's accessible and usable.

It creates a single, authoritative document that captures fire safety intent - one that future owners, future managers, and future fire authorities can rely on. Critically, it shouldn't sit in a drawer once produced. It needs to be kept live: updated after works, revisited when occupancy changes, and used as the reference point for any future alterations.

Is it a legal requirement?

There's no single law that says "every existing building must have a RFS". However, under the Regulatory Reform (Fire Safety) Order 2005, Responsible Persons must demonstrate that adequate fire precautions are in place. Where documentation is absent or unreliable, an RFS is increasingly the most credible and defensible way to meet that duty.

For higher-risk buildings under the Building Safety Act, the Safety Case requirements make documented fire safety information effectively mandatory. For all other properties, the cultural and regulatory expectation is clear: proactive, documented safety management is expected — not reactive firefighting.

What should you do?

If you're a managing agent responsible for a residential block:

• Ask the question. Does the block have a current fire strategy document? 

• Check the FRA. Does it flag unresolved questions about compartmentation, structural fire protection, or the basis of the evacuation strategy? If so, an RFS may be the right next step.

• Don't wait for an incident or enforcement notice. Commissioning an RFS proactively is far less disruptive and costly than responding to enforcement action or an insurer declining cover.

• Ensure competence. It is critically important that an RFS should be prepared by a qualified, competent and experienced fire safety consultant – seek confirmation of this before appointment and the PII they hold.

• Treat it as a living document. Once produced, integrate it into the block's ongoing fire safety management - not filed away and forgotten.

A final thought

Grenfell changed much about how we approach fire safety in residential buildings. The regulatory framework has moved, and the consequences of getting it wrong are more serious than ever.

An RFS will not solve every problem. But it will tell you clearly what the fire safety position is – and what needs to happen next, which for many properties is exactly the starting point they need

Anthony Walker FRICS FCIOB MIFireE, Director, Sircle UK