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Legal requirements for recording an FRA


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Hi all, quick question;

I have just joined a retail company as part of the facilities management team. We have around 30 stores covering england, scotland and ireland.

Having recently joined the company, i have noted that there are very few FRA's carried out for our stores. I understand that under the regs that you must conduct an FRA but only record it if you employ 5 or more persons.

All of our stores only have 3 or 4 employees. Some landlords have requested documented FRA’s which we have had to adhere to whether we have 5 or more employees or not.

I would still like it clarified to me that we are not required to provide a written FRA for those stores which do not employ 5 or more members of staff.


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The Responsible Person is the employer (art 3) i.e. the CEO or if it is a Limited company then it’s a corporate responsibility of the board. The RP is responsible for conducting a FRA (art 9) and guidance on written FRA can be found in the Regulatory Reform (Fire Safety) Order 2005 Guidance Note No. 1: Enforcement, which states,

Clause 57

“The Order contains a requirement to record the “prescribed information” if five or more persons are employed in order to maintain consistency with health and safety legislation. The prescribed information comprises the significant findings of the risk assessment (including the measures taken or to be taken, e.g. training and maintenance, consultation and co-ordination) and any group of persons identify as being especially at risk. Under the Order, the threshold of five or more persons includes those employees who may work from or in another place away from the premises concerned, for example an employer with three shops, each of which has two staff would employ six people and thus be under a duty to record the risk assessment for each shop”

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