Fire Risk Assessment: Who Is Responsible in Your Warehouse

Walk into most warehouses in the UK and you will find a fire risk assessment somewhere in the filing system, usually last reviewed a few years ago by whoever was in post at the time. Ask five people on site who the current responsible person is and you will likely get five different answers, none of them confident.

This matters. Getting it wrong is not just a paperwork problem. The Regulatory Reform (Fire Safety) Order 2005 (the RRO) puts real obligations on specific individuals, and those individuals can be prosecuted.

Who the Law Points To

The RRO does not use phrases like “fire safety officer” or “H&S manager.” It uses the term “responsible person,” and it defines that person by control, not by job title.

If you are an employer with any degree of control over the premises, you are a responsible person. If you own the building and lease part of it to a tenant, you may also be a responsible person, to the extent of your control over the common areas or structure. On a site with multiple occupants, there can be more than one responsible person, and they are expected to coordinate.

For the typical warehouse scenario, the responsible person is the employer, or whoever manages the operation from that site. If you lease a unit on a distribution park, you hold responsibility for the parts you control: your racking, your processes, your materials, and the safety of your employees and anyone else likely to be on the premises.

The responsible person does not need to carry out the fire risk assessment themselves. They can appoint a competent person to do it. But they remain accountable for ensuring it gets done, that it is suitable and sufficient, and that the findings are acted on.

What “Suitable and Sufficient” Means in Practice

The assessment needs to cover the actual hazards on your site. In a warehouse, that means stock type, storage height, racking configuration, ignition sources (charging points, machinery, electrical panels), escape routes, means of raising the alarm, and the occupancy profile, including shift patterns and any contractors on site.

A generic template downloaded from the internet and filled in with a tick or two is unlikely to hold up if there is a fire. The assessment needs to reflect what is actually happening in your building.

The responsible person also needs to ensure that findings are recorded (required if you have five or more employees), and that staff are informed of the significant findings and the protective measures in place.

When the Assessment Must Be Reviewed

There is no fixed statutory interval. The RRO says the assessment must be reviewed “regularly” and when there is reason to think it is no longer valid.

In practice, most insurers and enforcement officers expect to see a review at least annually for warehouse operations, given that stock, layouts, and processes change frequently.

You must also trigger an unscheduled review when:

• There has been a significant change to the premises, such as a new mezzanine, extended racking, or altered escape routes
• New materials or processes have been introduced that change the fire load or the risk profile
• There has been a fire or a near miss
• An inspection by the fire authority has raised concerns
• There has been a significant change in the number of people on site, including a new shift pattern or the introduction of agency staff

The key phrase is “reason to think it is no longer valid.” If something has changed and you have not looked at the assessment since, that is the reason.

Nominating and Recording the Responsible Person

Because the responsible person is defined by control rather than by appointment, there is no legal requirement to formally nominate someone. But in a warehouse with multiple managers, absent owners, or a management structure that has changed over time, it is worth being explicit.

Putting the responsible person’s name on the assessment itself, and reviewing that name when the assessment is reviewed, removes the ambiguity. It also makes it clear in an emergency, or during an inspection, that someone owns this document and is accountable for it.

If the person with control changes, such as a new operations manager taking over, the assessment should be reviewed at that point. A document signed off by someone who left two years ago is not a live document.

Keeping It Current Without Making It a Project

The assessment does not need to be a thick report. For a straightforward warehouse, a clear record of the hazards identified, the control measures in place, and the actions outstanding is sufficient. What matters is that it reflects the current state of the site.

Building the review into an existing audit cycle helps. Quarterly walk-rounds, annual insurance renewals, and routine maintenance checks are all natural triggers. The review does not have to be a standalone event.

If your warehouse audit process is patchy or informal, the waste and loss diagnostic at https://losses.cadencestandard.com is worth working through. It is built for manufacturing and warehouse operations and surfaces gaps that formal assessments sometimes miss. For the floor-level conditions that accumulate quietly over time, the 5S tool at https://5s.cadencestandard.com covers the housekeeping basics that sit underneath a lot of fire risk: clutter, blocked routes, and materials with no fixed home.