Last reviewed 4 June 2020

Failures in fire risk management are often cited as a contributory factor in serious fires. Mike Sopp looks at how a formal fire safety management system can address flaws in your processes, and how the new BS 9997 can help.

UK fire safety legislation aims to ensure that people at risk from fire remain safe thanks to the application of appropriate general fire precautions, which have been identified as necessary through the fire risk assessment process.

Government guidance notes that good management of fire safety “is essential to ensure that any fire safety matters that arise are always effectively addressed”. This is where a formal fire risk management system or fire safety management system (FSMS) can bring huge benefits.

Drivers for an FSMS

Article 11 of the Regulatory Reform (Fire Safety) Order 2005 (or the equivalent in Scotland and Northern Ireland) requires the responsible person/duty holder to make and implement arrangements for planning, organising, controlling, monitoring and reviewing the preventative and protective fire safety measures required by the legislation.

Enforcement guidance to the Order notes that the purpose of Article 11 is to “require effective management control of the fire safety arrangements in the premises” and must be “appropriate, having regard to the size of (an) undertaking and the nature of its activities”.

In a similar approach, the National Fire Chiefs Council guidance document on the application of the Order states that “the important aspect of this article is that fire safety is managed and that the elements of the arrangements are being addressed”.

Best practice in the form of BS 9999:2017 Fire Safety in the Design, Management and Use of Buildings. Code of Practice makes reference to “management levels” for fire safety, based upon different combinations of fire growth rate and occupancy risk profile as follows:

  • a Level 2 system would entail good practice to ensure conformity with legislative requirements

  • a Level 1 system would entail best practice to ensure conformity with a management system standard.

Although BS 9999 provides detailed guidance relating to specific functions, whether of the individual or within a management level, it does not provide a management framework within which the above can be applied.

With evidence suggesting that the risk from fire is now governed more by the quality of fire risk management rather than in the design of premises or fire protection measures, the need to have a documented framework so as to meet legislative requirements is clear.

Criteria and benefits of an FSMS

The responsible person needs to decide whether a formal FSMS is required within the organisation.

There are no specific criteria to determine when a system should be implemented, but in general terms the following questions may influence the decision.

  • Is an organisational and/or strategic approach to fire safety required? For example, if clarity is required within the organisation as to roles, responsibilities, authorities and accountabilities for fire safety or formal governance arrangements in the higher echelons of the organisation.

  • Does the organisation have multiple sites and/or a large geographical footprint? This would demand a continuity of approach at all sites in relation to fire safety.

  • Are fire risks high? Enhanced fire risk management assurance will be required.

  • Does the organisation wish to set itself minimum standards for managing fire risks? For example, these could be based on the benchmarks provided in a recognised framework such as national or international standards.

The implementation of an FSMS can benefit an organisation in many different ways. Examples include:

  • increased assurance that all legislative requirements have been identified and that the organisation is fully compliant

  • improved overall management of fire-related risks in line with the risk-based UK fire safety regime

  • a consistency of approach across multiple sites to the management and control of fire risks

  • ensuring that the aspirations, objectives and goals contained in the fire safety policy are put into action

  • a better allocation of resources to enable risks to be managed to as low as reasonably practicable

  • a cradle-to-grave approach to fire risk management in premises from design, through build, use, refurbishments and disposal particularly in “fire-engineered” premises

  • independent verification that fire risks are being managed through third-party certification of the system

  • assurance for internal and external stakeholders that fire risks are being well-managed and that the organisation can react to changes in the fire risk profile.

Having determined that a formal FSMS is necessary, organisations can then make reference to best practice in this area.

How BS 9997 can help

BS 9997:2019 Fire Risk Management Systems. Requirements with Guidance for Use provides a framework for a formal management system.

The standard utilises the Plan-Do-Act-Check model which is an iterative four-step management method used for the control and continuous improvement of processes and/or products. The four steps can be described in summary as:

  • Plan: establish the objectives and processes necessary to deliver results in accordance with the organisation’s fire policy

  • Do: implement the processes

  • Check: monitor and measure processes against fire policy, strategic objectives, legal and other requirements, and report the results

  • Act: take actions to improve fire risk management performance continually.

By using the PDCA model, BS 9997 ensures consistency with other “protective discipline” standards such as those for health and safety and business continuity management.

It also follows the high level structure introduced by the International Standards Organisation (ISO) that is being adopted for revised and newly developed management standards.

Interestingly, the standard makes reference to the Grenfell fire as well as fire safety in the construction process, stating that “the adoption of BS 9997 is expected to improve accountability and help create an audit trail, ensuring that the management of all stages of design and construction can be tracked through robust change control processes”.

Although following the broad annex SL approach, the standard does contain certain clauses that are unique to the standard.

For example, under Clause 6, BS 9997 contains clauses for:

  • planning for change including the purpose and consequences of that change

  • the development of a fire risk management strategy.

This clause links this standard with BS 9999, which also makes reference to a fire risk management strategy, stating that it is a “document which defines the organisation’s fire risk management system and method of implementing overarching policy”.

In Clause 7 (Support), the standard makes reference to “organisational knowledge”, which is information that is used and shared to achieve the organisation’s objectives, stating that this should be documented in the fire risk strategy.

As would be expected, a key element of the recommended management system is the need for a fire risk assessment programme and emergency planning.

The clause commentary in relation to emergency planning states that “these procedures should seek to prevent or mitigate the consequences of any such occurrence, including the continuity of the business operations”.

In this way, BS 9997 not only encourages the management of fire risks to people but can also minimise risks to property, business continuity and the environment.


Fire safety management can be seen as an organisational risk that requires the application of a formal management system to manage and control those risks.

Application of such a formal management system can be beneficial to an organisation, not least in meeting legislative requirements.

However, implementation of a system will require commitment and resources in order to be successful. It is therefore essential to determine the cost-benefit ratio before setting up an FSMS.

Further information

The following are available from the British Standards Institution at

  • BS 9997:2019 Fire Risk Management Systems. Requirements with Guidance for Use

  • BS 9999:2017 Fire Safety in the Design, Management and Use of Buildings. Code of Practice.

See also the extensive Fire section on your product, with in-depth information and resources on: