Behind the Façade: How Fire Risk Assessment is Evolving After the Grenfell Tower Fire
In the wake of the Grenfell Tower fire, façade fire risk assessment has come under intense scrutiny, yet key misconceptions remain. Frameworks like PAS 9980 are often misunderstood as compliance checklists, rather than the risk-based methodologies they are intended to be.
As construction practices, material choices and workmanship vary across building eras, assessing external wall systems requires a more nuanced, evidence-led approach. In this interview, Global HSE’s Andrew Cooper, Andreas Marais and Keith Plowman explore the realities of façade assessments, the limits of desktop reviews, and the need for proportionate, integrated solutions that balance safety, practicality and asset value.
How do construction eras and misunderstandings of materials and PAS 9980 shape façade fire‑risk assessments?
Keith Plowman: Buildings tend to fall into two main categories. You have pre-2000 era buildings, which are generally built quite well. Then you get buildings from around 2000 until the Grenfell era. Some are good but we do come across some shockers.
Andrew Cooper: Another issue is the misconception that risk is binary: combustible equals replace, non-combustible equals safe. It isn’t that simple. The understanding of PAS 9980 is also an issue. It is a risk methodology, not a materials checklist. You can have all the right materials, but workmanship is often the key issue that undermines the integrity of the structure.
What misconceptions do clients commonly have when instructing a façade fire risk assessment?
Andreas Marais: A lot of people see PAS 9980 as a compliance document, which it’s not. People have a Fire Risk Appraisal of External Walls (FRAEW) done to identify faults in their building, but that’s not what the document is there for. The methodology behind it is well adaptable into a different process which would then give you the outcome that they are looking for.
AC: Clients also often assume that a desktop review will suffice and height alone determines risk, which isn’t true. They often think that an EWS1 form is the same as an FRAEW and the outcome is simple and is a pass-fail result.
An FRAEW is a robust risk assessment of the existing state of the building and its underlying issues. It’s showing what was built, and then it should identify proportionate deliverable solutions.
Why is a desktop review rarely enough for complex buildings?
KP: We have a relatively new building. The documentation is fantastic and managed through a system that will feed into the future ‘golden thread’ of information.
What we don’t have is robust photographic evidence of how those materials were installed. The drawings can show they’ve got cavity barriers in the right place, and they are the right materials, but that doesn’t consider how it was fitted.
So sometimes you do need to have that intrusive investigation, even if it’s a much smaller scope than you would do without the documentation just to prove that what you find is on the site.
AC: It’s like having the “Rolls-Royce” of document management systems and detailed records from the original build, but if you’ve not backed it up with photographic evidence, you’ve always got that uncertainty.
What does a robust intrusive FRAEW involve?
KP: If you’re instructed to undertake an FRAEW on a building that had little or no documentation, you need to strike a balance between not stripping every single façade off the building to see exactly what’s there. You would need to target key locations but make sure you target enough areas to obtain a representative sample.
In terms of putting a number on that, the bigger and more complex the building the more openings you would look to make on that façade system to understand what’s going on behind the surface.
AC: Whatever we do has to be defensible and hypothesis led. It means that clients and third parties can have confidence in the approach.
Typical inspection locations might include slab edges, window heads, and sills. The inspection strategy must reflect the actual construction type. The aim is to get the maximum value for the client while causing the least disruption or damage to the building.
Crucially, we’ve got to identify the insulation, membranes, sheathing boards and other concealed type. Remediation strategies will be very different for a concrete frame building compared with a timber frame structure, for example.
AC: Now we have a black and white approach — maximum intervention, replace everything or make it non-combustible. Instead, it should be maximum risk reduction against a practical background. The other thing is that it is very rarely a single solution. It’s typically a combination of measures, tailored to the building and the specific risks involved.
Another important consideration is that it’s not only about life safety. It’s also about asset value. How do we maintain value in the asset? How do we maximise that? How do we help the client realise that value further down the line and protect the building and their investment?
Where does façade remediation intersect with fire strategy, compartmentation, structural constraints and building performance?
AC: The fundamental thing is that a façade solution can’t be done in isolation without the fire strategy. The fire strategy must be a fundamental driver of the outcomes FRAEW as well as findings.
The FRAEW and solutions proposed in relation to any façade remediation should align with the strategy assumptions, as well as with structural constraints, MEP systems and the long-term durability of the building. But it also needs to tie into what we’re going to use the building for in the future. What we don’t want is a poorly integrated approach that creates further problems down the line, and we’ve come across that quite a bit.
How do you manage façade remediation on occupied buildings while minimising disruption?
AM: That would be a building specific case in each instance, but you could sequence your work to different levels or areas. It’s always going to be disruptive in a way, but everyone will endure the same level of disruption. There will be the obvious things of noise and things like that, but there are some things that you can mitigate.
AC: It’s all about the planning, pre[1]engagement, strong communication with the client and residents or tenants about how we’re going to approach and minimise guest disruption.
Achieving a clear plan always relies on strong collaboration with the client, and when that partnership is in place, the process runs smoothly. Challenges tend to arise when communication, planning or expectations aren’t fully aligned, which is why early clarity is so important.
Where is façade risk assessment heading over the next three to five years?
AM: Something that is lacking is where an FRA will be done on a building. They might identify some cladding there that they say ‘I’m not sure so let’s prompt an FRAEW’ which is the usual route to an FRAEW but then it’s never really fed back.
Essentially, you’ll have two documents living alongside each other. What the Single Building Assessment (SBA) in Scotland has done is combined them to become a single source of key information on that building.
AC: I think there’ll be a great scrutiny of assessor competence and lower tolerance for uncertainty, stronger audit expectations, more digital traceability and increased emphasis on proportionality. We can see that with the confusion now in relation to buildings that fall either tolerable or medium.









