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FSO 2005 evidence trail

How FRA Flow supports the duties under the Regulatory Reform (Fire Safety) Order 2005 with a per-paragraph evidence trail.

By Richard Pryce·Last updated

The Regulatory Reform (Fire Safety) Order 2005 (commonly the "FSO 2005") is the legal framework that puts a fire safety duty on the responsible person for non-domestic premises and the common parts of residential buildings. BS 9792 is the standard that sits underneath it; the FSO is the law. This page is the short explainer of what the FSO requires of an FRA, and how FRA Flow's evidence trail meets that bar.

What the FSO expects of an FRA

Three duties most relevant to assessors:

  • A suitable and sufficient assessment of the fire risk in the premises (Article 9). "Suitable and sufficient" is the legal language; in practice it means the assessment must cover everything that could reasonably affect fire safety and explain its conclusions clearly enough to defend.
  • Records of the assessment kept in writing, particularly for premises with five or more employees or where a license applies (Article 9(7)). For housing common parts, a written record is universal.
  • Review of the assessment regularly and after any significant change (Article 9(3)). The "next review date" is a commitment the responsible person makes when accepting the report.

The FSO does not specify a format. Standards (PAS 79, then BS 9792:2025) emerged to give the industry a defensible default.

How FRA Flow supports the duty

FRA Flow's evidence trail is built so any FRA produced by the tool meets the "suitable and sufficient" bar by construction:

  • Every finding traces to a captured observation. The observation has a photo, a voice note, or a typed description, anchored to a location in the building.
  • Every paragraph in the report traces to its observation set. The audit trail records what evidence the AI was given and what it cited; the Show source panel surfaces the link interactively.
  • Sign-off is a named act. A specific reviewer signs off the report; their name is embedded in the PDF.
  • History is preserved. Re-runs of the assessment (annual reviews, post-incident re-assessments) keep the prior versions, so the responsible person can show the FRA's evolution over time.

The audit trail covers what is stored per paragraph for years-later challenges.

What FRA Flow does NOT do

A few things the FSO requires that sit outside FRA Flow's remit:

  • Action close-out. The FSO requires the responsible person to act on findings. FRA Flow records the action plan and (in a future milestone) tracks close-out, but the doing of the work is the dutyholder's responsibility, with their contractors.
  • Training records. The FSO covers staff fire-safety training; FRA Flow does not store training records.
  • Drills and tests. Same: out of scope.
  • Premises licences and other regulatory consents. FRA Flow is the FRA tool, not the broader compliance system.

Evidence longevity

For the audit trail to be useful five years later, it has to remain readable five years later. FRA Flow's commitments:

  • Reports are retained for the audit period agreed in your data-processing addendum (typically 7 years for housing contractors). Data residency covers the storage and retention details.
  • The evidence (photos, audio) is retained alongside the report. Soft-deleting the assessment does not destroy the evidence; it removes it from the active list, but it stays recoverable for the audit window.
  • The audit metadata is embedded in the final PDF, so a report copy that leaves the workspace still travels with enough metadata to identify what was assessed and when.

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