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EWS1 & PAS 9980

Who Needs a PAS 9980 Assessment?

Not every residential building needs a PAS 9980 assessment. This guide helps building owners, managing agents and freeholders understand when one is required.

22 October 2024 4 min read Fire Safety Services

PAS 9980 and Who It Applies To

PAS 9980:2022 is the British Standard setting out the methodology for carrying out a Fire Risk Appraisal of External Walls (FRAEW) on existing residential buildings. Since its publication, PAS 9980 has become the established standard for external wall fire risk assessments across the UK residential sector. But not every building needs one, and understanding when a PAS 9980 assessment is required — and when it is not — can save significant time and cost.

Buildings Most Likely to Need a PAS 9980 Assessment

A PAS 9980 FRAEW is most likely to be required for buildings that fall into the following categories:

  • Residential buildings with cladding or render systems — any residential block where the external wall incorporates a cladding system, external wall insulation system (EWIS), or render over insulation, regardless of height. RICS guidance requires an EWS1 form — which must be underpinned by a PAS 9980 FRAEW — for buildings of any height with such systems.
  • Buildings with combustible balconies — residential blocks of any height where balconies are constructed from or incorporate combustible materials such as timber decking, GRP, or certain composite materials.
  • Buildings over 18 metres registering with the BSR — higher-risk buildings being registered with the Building Safety Regulator must prepare a building safety case. Where the external wall fire risk position has not been established, a PAS 9980 FRAEW is required as part of the building safety case.
  • Buildings with leaseholders trying to sell or remortgage — where a leaseholder's mortgage lender has requested an EWS1 form, a PAS 9980 FRAEW is the technical assessment required to support that form.
  • Buildings with known cladding concerns — where a fire risk assessment or other survey has identified concerns about the external wall fire safety position, a PAS 9980 FRAEW provides a definitive engineering assessment.

RICS guidance updated in 2021 limits the circumstances in which lenders can require an EWS1 form — and therefore a PAS 9980 FRAEW. Not every residential building needs one. If you are unsure, a brief desktop review by a competent fire engineer can establish whether a full assessment is required.

Buildings That Typically Do Not Need a PAS 9980 Assessment

The following categories of building generally do not require a PAS 9980 FRAEW:

  • Low-rise buildings with entirely non-combustible external walls — buildings typically under 11 metres with external walls of brick, stone, concrete, or rendered masonry without combustible insulation, and with no balcony concerns, generally do not trigger a lender requirement for EWS1
  • Buildings that already hold a valid EWS1 form — where a compliant EWS1 form has been issued following a PAS 9980 FRAEW and the building has not materially changed, the existing form remains valid
  • New build buildings — PAS 9980 applies to existing buildings. New buildings should have demonstrated external wall fire safety compliance through the building control or BSR gateway process

The Freeholder's Obligation

Where a PAS 9980 FRAEW is required, the obligation to commission it rests with the freeholder or building owner — not with individual leaseholders. Leaseholders who are unable to sell or remortgage because of an absent or unsatisfactory EWS1 form should approach their freeholder or managing agent to request that an assessment is commissioned.

Under the Building Safety Act 2022, freeholders of higher-risk buildings have enhanced obligations around fire safety documentation. Where a PAS 9980 FRAEW is required as part of the building safety case, the accountable person must ensure it is obtained.

Getting Clarity on Your Building

If you are unsure whether your building requires a PAS 9980 assessment, Fire Safety Services can carry out a brief desktop review of available information — typically drawings, photographs, and any existing survey reports — to provide an initial view on whether a full FRAEW is likely to be required. This initial review can save the cost and delay of commissioning a full assessment for buildings where one is not needed.

Frequently Asked Questions

Does my block of flats need a PAS 9980 assessment?
It depends on the external wall construction and height of your building. Blocks with cladding, render over insulation, or combustible balconies of any height typically need an EWS1 form underpinned by a PAS 9980 FRAEW. Blocks with entirely non-combustible external walls and no balcony concerns under 18 metres may not.
Who is responsible for commissioning a PAS 9980 assessment?
The freeholder or building owner is responsible for commissioning a PAS 9980 assessment. Individual leaseholders cannot be required to pay for the assessment, though they can request that the freeholder commissions one where it is required for a sale or remortgage.
Can a PAS 9980 assessment be carried out without site access?
A desktop review can establish whether a full FRAEW is likely to be required. A full PAS 9980 FRAEW requires a site inspection and, in most cases, some degree of intrusive investigation to verify the external wall construction.
What if the freeholder refuses to commission an assessment?
Freeholders have a legal obligation to maintain fire safety in their buildings. Where a freeholder is unresponsive, leaseholders can seek assistance from their local authority, the Building Safety Regulator, or the Leasehold Advisory Service (LEASE). The BSR has powers to require building safety documentation from accountable persons.
Is a PAS 9980 assessment the same as a fire risk assessment?
No. A fire risk assessment under the RRO 2005 focuses on the overall management of fire risk in an occupied building. A PAS 9980 FRAEW specifically assesses the fire risk associated with the external wall system. Both may be required for the same building but they are distinct documents.

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