Is EWS1 the same as an FRAEW?

Following difficulties with being able to obtain and interpret assessments under the series of Advice Notes from MHCLG (now called the Department of Levelling-Up Housing and Communities, DLUHC), in an effort to simplify the process for building managers and mortgage lenders, RICS first issued the EWS1 process in December 2019.   Further guidance around the EWS1 process has been issued which clarifies which buildings it applies to.  This means that generally it will apply to residential and mixed used buildings over 18 metres, but also smaller buildings with particular types of unsafe cladding.  For simpler buildings where it can be easily proven that the cladding and balconies meets the requirements of Part B of the building regulations (specifically the November 2018 update which requires that all cladding, and attachments such as balconies must be A1 or A2-s1,d0).  Whilst the Part B of the building regulations has been updated further since, including updates in March 2024, the 2018 update was significant in that it introduced the prescriptive requirement for materials in the external wall (including balconies and decking) to meet the requirements of Classification A2-s1, d0 or Class A1.  Where this requirement is not met, a more detailed assessment will be required in order to determine whether the building requires remediation or not.  It is essential that an EWS1 form is completed by a person who meets the competency requirements to do so.  The outcome of the EWS1 process is:

Option A (A1,A2,A3)* where the materials are unlikely to contribute to the spread of fire.  In the case of option A3, there may be works need to replace combustible materials to attachments (usually replacement of timber decking or plastic composite decking to the balconies with non combustible decking, such as aluminium decking or non combustible composite such as Blazeboard),

Or

Option B (B1,B2) where there are combustible materials, and they are either deemed to be either not a concern (B1) or that remedial works will be needed (B2). 

This process lacked a detailed methodology for making a decision particularly between B1 and B2. 

Therefore in January 2022, PAS 9980 was published, which provides a methodology to carry out Fire Risk Appraisals of External Wall construction (FRAEW). 

This not only provides a more nuanced assessment of risk, taking into account various factors in a structured way, but also provides a structure for recommending temporary mitigations and proposed actions as well as the reasons for their recommendation. 

If I only have an EWS1 do I now need an FRAEW as well?

There has been an update to the guidance in relation to the use of PAS 9980 in 2024, and it remains the best way for competent persons to carry out Fire Risk Appraisals of External Wall construction in existing buildings (FRAEW).

This does not necessarily mean that an existing competently prepared EWS1 is obsolete.  The EWS1 is designed to last 5 years.  In most cases it would be unreasonable for a competently prepared EWS1 on a building which is established to be low risk to be prematurely superseded by PAS 9980.  But any new assessments should use the PAS 9980 format.  It is important to consider that the assessment process of PAS 9980 may yield a different result than the EWS1 form.

It is also important to note that PAS 9980 is not a method to establish compliance with building regulations.  Any new buildings must comply with the building regulations in force on the Effective Date upon which they were approved.   

Is an FRAEW the same as a Fire Risk Assessment?

No.  A Fire Risk Assessment prepared by the Responsible Person is intended to assess the general fire precautions to comply with the Fire Safety Order.  This should make reference to and take account of the findings of an FRAEW.  Usually a Fire Risk Assessor will not possess the specific competences to be able to carry out the FRAEW themselves, as these are two different areas of expertise.  In addition to taking account of the findings of the FRAEW, the Fire Risk Assessor will need information from the Responsible Person about the actions they have taken to address the mitigation and recommendations identified in the FRAEW. 

Is a Fire Risk Assessment the same as a Building Safety Risk Assessment?

No.  There is no set process for a Building Safety Risk Assessment, and it by definition will require input from a number of different specialisms, which will usually include:

• The building management (Responsible Person)
• The Fire Risk Assessor (in relation risk assessment in accordance with the Fire Safety Order)
• Structural Risk Assessor (in relation to assessment of structural risks, there is no set format for this yet established, but appropriate specialists such as Chartered Structural Engineers have access to guidance from the IStructE to assist them).
• Fire Risk Appraisals of the External Wall

This team of specialists will have determined the inherent risks in the associated parts of the building relevant to their specialisms (and each others). 

Then there is a process of analysing what could go wrong.  This relies on data and input from various stakeholders to identify the potential scenarios.  This should take account of all relevant factors, including:

• Tenure
• Modifications, deterioration and damage
• Other uses and adjacent uses (e.g. a takeway kitchen on the ground floor)
• Management and maintenance arrangements
• Safety management processes

The outcome should include a system of grading the highest risk actions and identifying actions to be taken to avoid or minimise these risks. 

The process and outcome should be recorded and made available to residents. 

*Note: The A1, A2 and A3 Options in EWS1 are different from the A1 and A2-s1,d0 ratings applied in Approved Document B (Regulation 7).  The A1, A2 and A3 Options in EWS1 are specific to the EWS1 form and do not have any application outside of the EWS1 process.  Whereas the  A1 and A2-s1,d0 classifications referred to in Approved Document B are combustibility ratings for materials when tested in accordance with EN13501-1.  EN13501-1 is an adopted European classification system which grades the classification of materials depending on their resistance to combustibility.  A1 is the highest rating (applies to Blazeboard).  Grade F is the lowest rating (i.e most flammable).  In the example of balcony decking, Grade F would apply to plastic composite decking (some may be slightly better than F, but even with additives plastic composite decking cannot achieve the A1 and A2-s1,d0 rating required by Regulation 7).  Aluminium decking can achieve the A2-s1,d0 with the right coatings.  It is also important that all of the components of the decking system are rated to A1 or  A2-s1,d0 as well.  This test applies to each individual component of the decking system such as the non-combustible pedestals, fixing clips and screws etc.  So it is important to use a fully certified system.  BBA certified materials provide the best level of assurance that all of the materials are fully certified.