Do Flats Without Communal Areas Need a Fire Risk Assessment?

If you own or manage a building containing two flats with separate entrances, you might assume a fire risk assessment is unnecessary because there is no communal hallway. It is a reasonable question, but the layout of the entrances is only one part of the picture.

The building may still have shared external areas, structural features and walls or floors separating the properties. These all need to be understood when deciding what fire safety responsibilities apply.

At The HSRA, we provide professional fire risk assessments for property owners and managers. In this article, we explain what to consider when two flats have separate entrances and no shared internal hallway.

Does a Building With Two Flats Need a Fire Risk Assessment?

A building containing two flats may need a fire risk assessment even if there is no shared internal hallway. Separate entrances do not automatically remove fire safety responsibilities.

In England and Wales, fire safety law covers relevant parts of buildings containing two or more sets of domestic premises, including the structure, external walls and any common parts. The assessment should reflect the building’s actual layout and use.

Government guidance for small blocks of flats in England also covers some buildings where each flat has its own private exit and there are no shared internal spaces. If you are unsure how the rules apply to your property, a competent assessor can help establish the appropriate scope.

This article focuses on England and Wales. Fire safety legislation differs in Scotland and Northern Ireland, so the relevant requirements should be checked for properties there.

What Counts as a Communal Area?

A communal area is a part of the property used by more than one household. In a block of flats, this could be an internal hallway, staircase or landing.

However, shared areas are not always inside the building. Depending on the layout, a shared entrance passage, external walkway or route used by residents to leave the property may also be relevant.

Two front doors opening directly outside do not necessarily mean there are no shared parts elsewhere. Before deciding whether an assessment is required, consider the whole property and how residents access and leave it.

Why Does the Building Structure Matter?

Even when flats have separate entrances, they may share parts of the building’s structure. Walls and floors between the properties can play an important role in limiting the spread of fire and smoke.

This separation is often referred to as compartmentation. It is particularly important in converted properties, where alterations, service installations or previous building work may have affected the construction between flats.

A fire risk assessor will consider the available information and what can reasonably be seen during the agreed assessment. If there are concerns that cannot be resolved through a visual inspection, further specialist investigation may be recommended.

What About External Walls and Doors?

The external walls of a building containing flats are relevant to its overall fire safety. The construction of the walls and any features attached to them should be considered as part of an appropriate assessment.

The position of the entrance doors also matters. A flat entrance door opening onto a shared internal hallway needs to be considered in relation to that shared escape route, while a door opening directly outside should be considered in its relevant external wall and building context.

An assessment does not automatically mean every door needs replacing or that every building needs an intrusive survey. The findings should be proportionate to the property and the risks identified.

Who Is Responsible for Fire Safety in a Building With Flats?

Responsibility depends on who has control over the relevant parts of the building. This could be the freeholder, landlord, managing agent, residents’ management company or another person with responsibility for the premises.

In some properties, more than one person or organisation may have a role. For example, a managing agent may arrange the assessment while a freeholder is responsible for certain repairs.

If responsibilities are unclear, check the ownership and management arrangements and establish who controls the building’s structure, exterior and any shared areas. The people involved should cooperate so that important parts of the property are not overlooked.

Does It Matter If the Flats Are Rented or Leasehold?

The layout and management of the building are important whether the flats are rented or occupied by leaseholders. The ownership arrangements can affect who is responsible for particular parts of the property and how access or repairs are organised.

A landlord of an individual flat may also have separate housing and fire safety obligations within the property they let. These should be considered alongside any responsibilities relating to the wider building.

If you manage a converted house, it is worth checking that your existing fire safety information reflects the way the property is occupied today. Changes made during a conversion or later refurbishment can affect the risks that need to be considered.

What Will a Fire Risk Assessment Consider?

The scope depends on the building, its layout and the areas under consideration. For a small building containing flats, an assessor may need to look at:

• The building’s layout and how residents enter and leave.
• Any shared internal or external areas.
• The visible condition of relevant walls, floors and other structural features.
• External walls and associated features.
• Relevant entrance doors and their relationship to escape routes.
• Existing fire safety information and any concerns raised by the people managing the property.

The assessor should explain what has been included, any areas that could not be accessed and whether further information or specialist advice is needed. The report should also provide clear recommendations where improvements are required.

A fire risk assessment is not necessarily a detailed inspection of every feature inside each private flat. Its scope should be agreed and explained before the assessment takes place.

What If There Is No Shared Area at All?

If each flat has a completely separate entrance and there appears to be no shared internal or external area, the position should still be considered carefully. The nature of the building, its structure, ownership and management arrangements all matter.

Government guidance recognises that maisonettes and other properties with separate entrances can require particular consideration. A competent assessor can review the circumstances and advise on the appropriate assessment and scope for your building.

Avoid relying solely on the description “no communal areas” when requesting advice. Explain whether the flats are within the same building, how they are accessed and whether they share structural elements or external routes.

Arrange a Fire Risk Assessment With The HSRA

At The HSRA, we help property owners and managers understand fire risks and their responsibilities. Our fire risk assessments provide clear reports and action plans tailored to the premises being assessed.

If you manage a building with two flats and are unsure what is required, contact our team. Tell us how the property is arranged, whether there are any shared areas and who manages the building, and we can discuss the appropriate next steps.

Contact The HSRA for a no-obligation quotation for one site or a nationwide property portfolio.

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