Fire Risk Assessment Audit Trail: What the Trail of Records Must Show

What is an audit trail in a fire risk assessment?

An audit trail is the record that allows someone who was not on site to reconstruct what was assessed, what was decided, what was left out and why, and every change made to the report afterwards, with a name and a date against each step. It sits behind the report rather than inside it. The report tells the responsible person what needs to be done. The trail shows how the report came to say it.

Two records are in play, and they are often confused. The first belongs to the responsible person. Since 1 October 2023, Article 9(6) of the Regulatory Reform (Fire Safety) Order 2005 has required the responsible person to make a record of the assessment or review, including all of the findings and the measures taken, not only the significant ones. The article on fire safety record keeping covers that duty. The second record belongs to the assessor. It is the working trail behind the report, and no template is handed out for it. This article is about that one.

Why does a fire risk assessor need an audit trail?

Because three parties will eventually ask an assessor to justify a report, and none of them accepts recollection as evidence.

The first is a senior colleague. In any practice with more than one assessor, a lead assessor reads the report before it is issued and asks why a section was excluded, why the risk rating landed where it did, or why a finding from the previous year’s report has disappeared. Without a record, the answer comes from memory, and memory is not evidence.

The second is an enforcing authority or a court. After a fire, the fire and rescue authority will want to know what the assessment said on the day it was issued, not what the file says now. If the report was edited after the incident, however innocently, and the edit was not recorded, the whole document loses its standing.

The third is an auditor. Third-party certification under a scheme such as BAFE SP205, registration with the National Fire Risk Assessor Register or the Institution of Fire Engineers, and regulated qualifications such as those from NEBOSH or FireQual all lead to the same point: someone samples the assessor’s reports and asks how each conclusion was reached. The trail is what gets handed over.

A fourth reason is easy to miss. Article 22A of the Order, also inserted in October 2023, requires an outgoing responsible person to pass the fire safety information for the premises, including the assessment record, to whoever takes over. A report outlives the person who commissioned it. The trail is what makes it usable by the next one.

What should the trail record for every assessment?

For each report issued, the following should be producible without reconstruction:

• Who assessed, when and against what. The assessor’s name, the date of the site visit, the methodology followed (PAS 79-1:2020, BS 9792:2025 or another stated method) and the version of the report issued.
• What was excluded and why. Every section or question marked not applicable, with the reason recorded in the assessor’s own words at the time.
• What the findings rest on. The observations, photographs, test records, drawings or previous reports relied on for each significant finding.
• What was recommended and by when. The action plan with priorities and timescales, and the status of each action where it is tracked.
• Who checked the report before issue. The reviewer’s name and date, any changes requested, and what was done in response.
• Every change after issue. What changed, who changed it, when, and why, with the earlier version still available.

None of this requires a system. A dated notebook, a versioned folder and a consistent habit are enough. What matters is that the record is made at the time, cannot be quietly rewritten later, and can be handed to a stranger.

Why does an excluded question need a written reason?

Because a blank looks like an oversight, and a reason looks like a decision.

Take a single-storey shop with no sleeping accommodation. The assessor skips the questions on evacuation of sleeping occupants. That is obviously right, and it is also invisible on the page. Two years later, after a change of use, a colleague reviewing the file cannot tell whether sleeping risk was considered and dismissed or never reached on the checklist. One line, “no sleeping accommodation on the premises at the date of assessment”, turns an omission into a judgement. It also protects the assessor, because it fixes what the building was when it was seen.

The same applies to any question answered “not applicable”, any section left out of the report, and any recommendation from the previous assessment that is treated as closed. The reason should be written at the time. It does not need to be long. It needs to exist.

What happens when a report is amended after sign-off?

Every amendment after sign-off is a new version, and the previous version stays on record.

This is where trails most often break. The client calls about a typo in the address, or the assessor notices that the risk rating on one finding should have been higher, and the quickest fix is to open the file, correct it and send it again. The result is two documents claiming to be the same report, with no way of telling which one the responsible person acted on.

The rule is simple. An issued report is never overwritten. A new version is issued with a new date, the old one is kept, and the record states what changed, who changed it, when and why. If the change affects the findings or the action plan, the responsible person is told in writing, because they have been relying on the earlier version. Where the practice has a review or validation step, an amendment after sign-off goes back through it. A corrected report that nobody has re-checked is no longer a signed-off report.

What do certification schemes and registers expect?

They expect the trail, and they expect it to survive.

BAFE SP205, the UK certification scheme for organisations providing fire risk assessment, expects records of all work to be kept and readily accessible for seven years, and expects documents to be kept in a way that shows every change made along the way, the scheme’s own example being tracked changes. It also expects a short validation record for each report: who assessed it, who checked it, when, and what was corrected.

Professional registers work the same way with less paperwork. The National Fire Risk Assessor Register and the Institution of Fire Engineers both assess competence against real reports and sample work at renewal. A regulated qualification, whether from NEBOSH, FireQual or another awarding body, shows that the method was taught; the trail shows that it was applied in a real building on a real day. Whichever route an assessor takes, the question at the end of it is the same: show how the conclusion was reached.

How long should the trail be kept?

At least seven years from the date of the report, and longer where the premises carry a sleeping risk or the report has been relied on in a dispute.

Seven years is the SP205 minimum and comfortably covers the six-year limitation period for most civil claims in England and Wales. It also spans the period in which a responsible person is likely to change, so the record is still available when the incoming one requests it under Article 22A. The trail should be kept with the report it belongs to, not in a separate system where the link can be lost.

Frequently Asked Questions

Is the audit trail part of the fire risk assessment report?

No. The report is written for the responsible person and their duty under Article 9 of the Fire Safety Order. The trail is written for whoever checks the report: a reviewer, an auditor, an enforcing authority or a court. Some assessors append a summary of exclusions and amendments to the report itself, which is good practice, but the full trail with dates, names and superseded versions is a separate record kept by the assessor.

Can the trail be kept in a notebook or in email?

Yes, provided each entry records who, what and when, is made at the time rather than reconstructed later, and cannot be edited without leaving a mark. A dated site notebook and a versioned folder of PDFs meet that test. A single Word file edited in place does not.

Does the responsible person need to see the assessor’s trail?

The responsible person needs the record of the assessment, which is the report and its findings. They do not usually need the assessor’s working trail, but they are entitled to ask how a finding was reached, and an enforcing authority can ask either party. The trail should allow an answer within a day, not a week.

Does this apply to a self-employed assessor whose reports nobody reviews?

More so. A sole assessor has no colleague to catch a missed section or an unrecorded change, so the record is the only check on the work. If that assessor later applies for certification or registration, the reports already issued are the ones that will be sampled, and the trail behind them will decide the outcome.

FireRecord produces a separate Trail of Records for every assessment alongside the report: each excluded question with the reason given, every amendment after sign-off with who made it and when, and the validation record when a senior assessor signs the report off. Each generated version of the report stays archived, so the earlier version is always there when someone asks for it. Find out more at firerecord.co.uk.