From PAS 79-2 to BS 9792: What Actually Changed and What You Need to Do Differently
BS 9792:2025 has been live since August 2025, and most assessors working in housing have at least started thinking about the transition from PAS 79-2. But thinking about it and actually updating your templates, your on-site methodology, and the way you document your reasoning are different things.
This article is designed to help with that second part. It goes clause-by-clause through the changes that affect your day-to-day work — the structural shifts in the pro forma, the new expectations around documentation and evacuation, the formalised PCFRA framework, and the practical implications for how you capture and present your findings.
The headline: what kind of change is this?
PAS 79-2 was published in December 2020 as one half of the split from PAS 79:2012. It was always intended as a temporary measure — a Publicly Available Specification developed quickly because the housing sector needed dedicated guidance and couldn't wait for a full British Standard to go through the committee process.
BS 9792 is the permanent replacement. Published 31 August 2025 by BSI under Technical Committee FSH/14, it supersedes PAS 79-2 and carries the authority of a full British Standard. That distinction matters. A PAS is voluntary guidance. A British Standard is a recognised benchmark that enforcing authorities and courts reference when evaluating whether an assessment is suitable and sufficient.
In practical terms: if your reports still reference PAS 79-2 as the governing standard, they are referencing a withdrawn document. That doesn't make them invalid overnight, but it weakens their defensibility if challenged.
The structural reorganisation you'll feel on site
Clause 15 is now subdivided
Under PAS 79-2, Clause 15 — covering fire protection measures — was a single, undivided block. Assessors had to work through fire detection, means of escape, signs, emergency lighting, firefighting equipment, compartmentation, suppression systems, structural fire protection, external walls, smoke control, and FRS facilities as one continuous section.
BS 9792 breaks Clause 15 into twelve distinct subsections (15.1 through 15.12), each with its own commentary. This isn't cosmetic. It means assessors now have a clear, bounded scope for each element of fire protection, with specific guidance attached to each. When you're documenting your reasoning for accepting a departure from a prescriptive norm — say, a reduced travel distance compensated by sprinklers — you can now reference the exact subsection rather than pointing vaguely at "Clause 15."
For template builders, this is significant. Each subsection maps to a distinct section of the Annex A pro forma, which means your digital template needs twelve discrete fire protection capture points, not one large one.
FRA types are now formalised in the standard itself
PAS 79-2 described four types of housing FRA (Type 1 through Type 4) in its commentary, distinguishing between common-parts-only vs. common-parts-and-dwellings, and non-intrusive vs. intrusive. But the typology sat within the commentary rather than being presented as a structured framework with its own figure.
BS 9792 formalises this with Figure 3 — a clear visual matrix of the four FRA types — and moves the type descriptions into the body of Clause 5 (Principles and Scope). The types are now explicitly tied to the evidence threshold. Type 1 is only appropriate where there is evidence of building integrity (previous surveys, known construction standards, visual inspection results). Where that evidence is absent, the standard makes clear that Type 1 may not be sufficient.
This is a direct workflow change. Under PAS 79-2, many assessors defaulted to Type 1 unless the client specifically commissioned something more invasive. BS 9792 shifts the burden: you need to justify why a Type 1 is appropriate, not why a Type 2 is necessary. If you can't evidence compartmentation integrity, the standard points you towards intrusive investigation.
The new pro forma: from Yes/No to Observation-Comment-Conclusion
This is arguably the most significant day-to-day change for working assessors.
PAS 79-2's Annex A pro forma used a binary structure for most fire protection topics. Each item presented a question, a Yes/No tick, and a field for "Relevant information (including description of arrangements and deficiencies observed)." PAS 79-2's own guidance warned that assessors should not let the pro forma become a tick-list — but the structure invited exactly that behaviour.
BS 9792 replaces this with a three-part structure for every fire protection topic: Observation, Comment, and Conclusion.
The Observation section is where you record what you actually found — the physical measures in place, the sources of your information (observed, understood, records indicate), and the factual state of affairs. The Comment section is where you discuss shortcomings, record justifications for accepting departures from prescriptive norms, and contextualise the assessment with positive findings alongside deficiencies. The Conclusion offers three options: Satisfactory, Action Required, or Not Applicable.
This three-part structure fundamentally changes the documentation requirement. Under PAS 79-2, an assessor could defensibly record "Fire doors — Yes — FD30S doors observed to flat entrances, some seals damaged." Under BS 9792, you're expected to separate what you found (Observation), what it means and whether it's acceptable (Comment), and what needs to happen (Conclusion).
BS 9792 makes this expectation explicit in Annex A, paragraph A.6: while it might not be essential to record further information in every section, care needs to be taken to ensure the pro forma does not become purely a tick-list with inadequate supporting information.
The implication is clear. Assessors who relied on checkbox-driven templates with minimal free text need to change how they document. The standard expects narrative reasoning, not just binary answers.
Risk-proportionate methodology: more than a buzzword
Both PAS 79-2 and BS 9792 advocate a risk-proportionate approach. But BS 9792 makes the practical implications considerably more explicit.
Benchmark standards as starting points, not endpoints
BS 9792 Clause 8 states that the recommendations in the action plan should be risk-proportionate, which might necessitate measures that are above or below those recommended in the relevant code of practice. Departures from recognised codes should be based on the assessor's judgement and take into account fire safety principles while adopting a pragmatic approach based on assessment of risk.
This is a notable shift in emphasis. Under PAS 79-2, many assessors treated government guidance (Approved Document B, LGA guidance, etc.) as a hard pass/fail benchmark. BS 9792 repositions that guidance as a starting point. If the evidence supports it, you can recommend less than the code says — and if the risk warrants it, you might need to recommend more.
The corollary is that you need to document your reasoning. BS 9792 Clause 10.4 requires that if any fire protection measure obviously and significantly departs from the standard recommended in a relevant guidance document, but no upgrading is recommended in the action plan, that acceptance must be justified within the documented FRA.
The decision tree for older buildings
BS 9792 includes Figure 4 — a decision tree for formulating action plans when existing premises do not conform to current standards. This was present in PAS 79-2 in a similar form, but BS 9792's commentary on Clause 9 is more direct: it is not necessarily the case that failure to comply with current guidance necessitates upgrading. Standards improve over time, but older standards are not inherently unsafe. Upgrading might even be architecturally impossible.
For assessors working across ageing housing stock, this is important guidance to consider. The standard explicitly supports the professional judgement needed to say "this building doesn't meet current norms, but it's acceptably safe" — provided you can articulate why.
Evacuation guidance: updated and more granular
Stay put, simultaneous, and the grey area between
BS 9792 retains the PAS 79-2 framework for evacuation strategies but gives significantly more attention to the circumstances that might warrant a temporary change from stay put to simultaneous evacuation. The commentary on Clause 15.2 explicitly references the NFCC guidance on temporary changes to simultaneous evacuation in purpose-built blocks of flats, and ties this to the cause-and-effect strategy of the fire detection and alarm system.
Practically, BS 9792 now expects assessors to consider and document whether the installed fire detection system is compatible with the building's evacuation strategy. In a purpose-built block of flats with a stay put strategy, a fire alarm system sounding in all dwellings simultaneously is not just unnecessary — it actively contradicts the strategy and can put residents at risk. The standard makes this connection explicit rather than leaving it to the assessor's background knowledge.
Temporary waiting spaces replace refuges
BS 9792 adopts the term "temporary waiting space" in place of the older "refuge" terminology (though it acknowledges the older term is still used in some jurisdictions). The definition is more precise: a designated area protected by fire-resisting and smoke-retarding construction, provided with a safe route to a storey exit, evacuation lift, or final exit.
Critically, BS 9792 notes that temporary waiting spaces are for short-period waiting until a means of evacuation becomes available. They are not areas where people are to be left indefinitely until rescued by the fire and rescue service. If your current templates still describe refuges in passive terms, the language needs updating to reflect this active expectation.
Inclusivity requirements: the PCFRA framework
This is the area where BS 9792 has moved furthest from PAS 79-2.
PAS 79-2 referenced person-centred fire risk assessments, but specific recommendations were explicitly described as outside the scope of that PAS. The assessor was expected to consider whether PCFRAs were needed, but the standard didn't provide a framework for carrying them out or a pro forma for recording them.
BS 9792 changes this substantially. Clause 21 now provides specific recommendations for how assessors should engage with the PCFRA process. The assessor should assess the adequacy of any processes in place for determining the need for, and carrying out, PCFRAs. If no process exists, this should be noted in the action plan. The FRA must take into account the information captured by any existing PCFRAs or person-centred emergency plans.
More significantly, BS 9792 introduces Annex D — a detailed informative annex on people with specific evacuation requirements. Table D.1 maps characteristics of occupants (cognitive, neurodiversity, sensory, mental health, physical, mobility) against their impact on escape and the types of measures that might be needed. This table is a practical tool for assessors who need to understand the range of characteristics they should be considering.
Annex E provides a model pro forma for conducting a PCFRA itself, structured as a nine-step process from determining resident characteristics through to setting a review date. BS 9792 clarifies that a PCFRA does not need to be undertaken by a fire safety specialist — it is intended for non-specialists who regularly engage with the resident.
For assessors, the practical impact is twofold. First, your FRA template now needs dedicated sections for recording PCFRA process adequacy and findings — these are no longer optional extras. Second, when you encounter housing providers who have no PCFRA process in place, the standard gives you clear authority to flag this in your action plan.
Documentation requirements: what the report must now contain
BS 9792 Clause 10 is more prescriptive than its PAS 79-2 equivalent about what a documented FRA must contain. The minimum requirements now include:
- The type and scope of the FRA that was carried out
- Name, contact details, qualifications, and certification of the assessor
- The name of any person who checked (peer reviewed) the report
- Details of external documents or information resources referenced
- The date the assessor inspected, the date of peer review, the date of issue, and the date proposed for next review
The commentary on Clause 10 adds a notable requirement about audience: the report needs to speak to two divergent audiences — those who know the premises but have little understanding of fire safety, and those unfamiliar with the premises but with a good understanding of fire safety. This dual-audience expectation should influence how you write, not just what you write.
BS 9792 also explicitly requires that significant areas of the premises to which access was not possible should be recorded, along with details of any known specific evacuation requirements — sufficient to confirm whether adequate measures are in place.
Legislative alignment: what's been updated since 2020
BS 9792 incorporates legislative changes that postdate PAS 79-2, including:
- Fire Safety Act 2021 — which clarified that the external walls and flat entrance doors of multi-occupied residential buildings fall within scope of the Fire Safety Order
- Fire Safety (England) Regulations 2022 — which introduced specific duties around fire door inspection frequency, provision of fire safety information to residents, and wayfinding signage in buildings over 11 metres
- Building Safety Act 2022 — establishing the Building Safety Regulator and creating a more rigorous regulatory regime for higher-risk buildings
BS 9792 also updates references to complementary standards published since 2020, including PAS 9980 (external wall fire risk appraisals), BS 9991:2024 (fire safety in the design and management of residential buildings), and the forthcoming BS 8674 (competence framework for fire risk assessors).
If your existing templates reference legislation only up to the Fire Safety Order 2005, they need updating to reflect these post-2020 additions.
What you should do now: a transition checklist
If you're an assessor or assessment firm working in housing, here's what needs to change:
Templates: Retire any template that references PAS 79-2 as the governing standard. Adopt the BS 9792 Annex A structure with Observation/Comment/Conclusion fields for every fire protection topic. Ensure Clause 15 maps to twelve discrete subsections.
FRA type selection: Document your rationale for the FRA type at the start of every report. If you're commissioning a Type 1, record the evidence that supports it.
PCFRA integration: Add dedicated sections to your template for recording PCFRA process adequacy and the findings of any existing PCFRAs or person-centred emergency plans.
Evacuation documentation: Record the evacuation strategy explicitly and confirm the fire detection system is compatible with it. Use "temporary waiting space" in place of "refuge" where appropriate.
Departures from guidance: Where you accept a departure from a prescriptive norm, document your reasoning in the Comment section — not just in a note at the back of the report.
Legislative references: Update your report headers to reference BS 9792:2025 and the current legislative framework including the Fire Safety Act 2021 and Fire Safety (England) Regulations 2022.
Peer review: If your reports are peer reviewed, record the reviewer's name and qualifications. BS 9792 includes this as a standard field in the pro forma.
How FireCheckr handles this
FireCheckr's housing templates are built to BS 9792:2025 from the ground up. Every fire protection topic maps to its own Observation/Comment/Conclusion capture point. PCFRA adequacy is a dedicated section in every housing assessment.
But the real difference isn't the template structure — it's the workflow. FireCheckr uses a capture-first approach: you talk, type, or photograph what you find on site, in whatever order makes sense. The platform's AI then structures your notes into the correct BS 9792 sections, separating observations from comments and mapping conclusions to the action plan. You never need to navigate dropdown menus or remember which clause you're in while you're standing in a corridor checking fire door strips.
The assessor is the expert. The platform handles the admin. That's how you produce BS 9792-compliant reports without spending your evenings reformatting templates.
If you want to see how this works in practice, book a demo and we'll walk you through a housing assessment end to end.
FireCheckr is the AI-powered fire risk assessment platform for professional assessors. We build tools that respect your expertise and remove the admin that slows you down.
