How many FRAs for a commercial building with flats above

[Ron]

Hello, I hope someone can assist.  Is there a definitive answer of how many FRA's are required for a building comprising:

• Building is owned by one person.
• Large RENTAL retail unit on the ground floor with independent escape routes.  Rented out by the building owner.
• 10 flats on the upper floors with independent escape routes.  Rented out by the building owner.

Is it three FRA's? 

1. One for the flats communal areas
2. One for the commercial
3. One for the entire building

Or is it two?

1. One for the flats communal areas
2. One for the commercial

Or is it something else??

Thanks for reading this far!

[AnthonyB]

It's all determined by who is a Responsible Person as per the definitions in the law:

- For the commercial unit it would be the tenant as they are both:
a) An employer having a degree of control over a workplace; &
b) A person having control of part of a premises for the carrying on of an undertaking (because they have a lease)

- For the flats it would be the person having control of the areas in common which would usually be the freeholder (although depending of the extent of their control the managing agent may be part of the mix in addition, but still 1 FRA either instructed by the agent or the freeholder direct)

So TWO FRAs with a legal duty to share relevant fire safety information and to account for all relevant persons

If the retail unit was vacant and thus back under the control of the freeholder then it could in theory be one building wide FRA, but as soon as a tenant moves into the unit there will be both changes to the premises and Responsible Person so you are back to TWO again