CQC Fire Safety Requirements
What inspectors actually check, and the records you need to be able to produce
Is fire safety part of a CQC inspection?
Yes — but not in the way most managers expect.
The Care Quality Commission is not the fire authority. Fire safety in England is enforced by your local fire and rescue authority under the Regulatory Reform (Fire Safety) Order 2005. A CQC inspector will not issue a fire safety enforcement notice.
What CQC does is assess whether your service is safe, and it treats fire safety as evidence under that key question. An inspector is not checking extinguisher pressure gauges. They are checking whether the people running the home understand their fire risk, can produce the paperwork that proves it, and have acted on what that paperwork told them.
That is a different test, and it is the one providers most often fail — not because the building is unsafe, but because nobody can evidence that it is.
📜 Legal and Regulatory Context
Two separate duties apply. The Fire Safety Order 2005 requires the responsible person to ensure a suitable and sufficient fire risk assessment is carried out and kept up to date, and is enforced by the fire and rescue authority. CQC assesses fire safety as evidence under the Safe key question, and also under Well-led where oversight is weak. Both regulators can ask to see the same documents.
Where fire safety sits in the CQC framework
Fire safety evidence is gathered under the Safe key question and bears on several quality statements — most directly Safe environments and Learning culture. It is also considered under Well-led, because a provider who cannot show oversight of fire risk is telling you something about its governance.
In practice that means fire safety can affect your rating through more than one route. A missing fire risk assessment is not a single tick-box failure; it is evidence about how the service is run.
A note on timing. CQC currently assesses under the single assessment framework — five key questions and 34 quality statements. CQC has said it is moving to four sector-specific frameworks, with the quality statements replaced by a smaller set of supporting questions and rating characteristics reintroduced. The evidence inspectors ask for on fire safety is not expected to change. The labels around it will.
The six things inspectors ask to see
1. A current fire risk assessment. The foundation. In a care setting, expect to justify anything older than twelve months, and expect to be asked what changed after the last review.
2. Personal Emergency Evacuation Plans. This is where care homes most often come unstuck. A PEEP is an individual evacuation plan for anyone who could not evacuate unaided. In a home where most residents have limited mobility, cognitive impairment or sensory loss, that means most residents need one — and each needs to be specific about how many staff, what equipment, which route, and what changes at night. Generic PEEPs, or PEEPs not updated after a resident's mobility declined, are a common and serious finding. Inspectors will often pick a resident and ask a member of staff on shift what that person's plan is.
3. Fire drill records, including at night. Daytime drills with full staffing prove very little about a building whose real risk is at 3am with two staff on duty. Inspectors look for night-time or minimum-staffing drills, and for what the records say went wrong. A drill log that never identifies a problem reads as a drill log nobody takes seriously.
4. Staff fire training and named fire wardens. Induction, refresher intervals, and a clear allocation of who takes charge. Records must be current for agency and bank staff too, which is a routine gap.
5. Evidence of maintenance and testing. Weekly alarm tests, emergency lighting, fire doors, and servicing of detection and suppression systems. What matters is the record showing it happens on schedule and that faults were closed out.
6. Action taken on identified risks. The most important item. A fire risk assessment listing twelve significant findings, none addressed eighteen months later, is worse for you than not having one — it demonstrates you knew and did nothing. Inspectors follow the audit trail from finding to completion.
The gaps that come up most often
- PEEPs that exist on paper but do not match the resident's current needs
- Fire doors wedged open, or hold-open devices not linked to the alarm
- Escape routes used for storage — wheelchairs, hoists, linen trolleys
- No night-time drill in the last twelve months
- An assessment carried out by someone with no demonstrable competence
- Action plans with no owner and no completion date
None of these are expensive to fix. Nearly all of them are cheaper to fix than to be found with.
Who can carry out the assessment?
The Fire Safety Order requires the assessment be made by a competent person. It does not require a specific qualification, which is precisely why the standard varies so widely.
For a care home the bar is higher than for an office, because sleeping accommodation and dependent occupants make the risk profile far more complex. If challenged by a fire officer or a CQC inspector you should be able to say who carried out the assessment and why they were competent to do it. "We used a template we found online" is not an answer that survives contact with either.
Frequently asked questions
Does CQC check fire safety directly?
CQC assesses fire safety as evidence under the Safe key question, but enforcement sits with your local fire and rescue authority. Both can ask to see the same paperwork.
How often does a care home fire risk assessment need reviewing?
There is no fixed statutory interval, but the assessment must be kept up to date. For care settings, annually is the working standard, plus a review after any material change — building works, a change in resident dependency, or an incident.
Do we need a PEEP for every resident?
For everyone who could not evacuate unaided. In most care homes that is the majority of residents, and each plan needs to be individual rather than generic.
What happens if we do not have a fire risk assessment?
The fire and rescue authority can issue enforcement or prohibition notices, and prosecution is possible. Separately, CQC can reflect the failure in your Safe and Well-led ratings, and failing to meet your fire safety duties can invalidate your insurance cover.
Will our insurer ask for it?
Commonly, yes. Insurers typically require the written report to be made available on request, and an out-of-date assessment can complicate a claim.
Fire Risk Assessments That Stand Up to Inspection
Applegarth Health and Safety carries out fire risk assessments for care homes across Bedfordshire, Cambridgeshire, Hertfordshire, Huntingdonshire, Essex and North London. Jeremy Applegarth holds the NEBOSH National Diploma and is a Member of IOSH, and visits personally. Reports cover the building, PEEPs, drill and training records, maintenance evidence and a prioritised action plan you can actually work through. Fixed fee agreed before the visit, written report within seven days, from £495.
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