When Does a Fire Risk Assessment Recommend a Variation Order?
28 Jul 2026 | By Ron Fellowes MIFSM, GIFireE, CertNCRQ
Costly fire alarm upgrades are not always the most appropriate outcome of a Fire Risk Assessment. Learn when a Fire Alarm Variation Order may provide a proportionate, risk-based solution and how it supports residential fire alarm compliance.
A Fire Risk Assessment is intended to identify the fire safety measures a building needs to achieve an appropriate level of protection. In some cases, this may include recommending significant upgrades to the fire alarm system. However, a standard upgrade is not always the most proportionate or appropriate solution.
This can create difficult compliance decisions for housing associations, managing agents, and Responsible Persons. You may be faced with costly upgrade recommendations or uncertainty about whether the proposed fire alarm strategy reflects the actual level of risk within the building.
This article explains when a Fire Risk Assessment may recommend a Fire Alarm Variation Order, what it means in practice, and how it can support a proportionate, risk-based approach to residential fire alarm compliance.
What Is a Fire Alarm Variation Order?
A Fire Alarm Variation Order is a formal, risk-based document that justifies an alternative approach to standard fire alarm guidance, typically BS 5839. It is used where a building’s risk profile, occupancy, or management arrangements support a different fire alarm solution.
Rather than recommending fire alarm upgrades as the default response, a variation order considers whether an alternative fire alarm strategy can provide an equivalent level of safety while remaining proportionate to the risks identified.
Responsible Persons can use a Fire Alarm Variation Order to justify an alternative fire alarm strategy, support discussions with regulators, enforcing authorities, freeholders, and other stakeholders, and demonstrate that the proposed approach is based on a structured, risk-based assessment.
Why Might a Fire Risk Assessment Recommend a Variation Order?
A Fire Risk Assessment may recommend a Fire Alarm Variation Order where the assessor concludes that standard fire alarm guidance does not represent the most appropriate solution for the building.
This may occur where:
- Existing fire alarm upgrade recommendations appear disproportionate to the level of risk
- The building’s fire alarm strategy has evolved over time
- Refurbishment or changes in occupancy have altered fire safety requirements
- The evacuation strategy differs from the assumptions within standard guidance
- Existing compartmentation and passive fire protection reduce the need for additional automatic detection
- Conflicting advice has been received from different fire safety professionals
The recommendation should always be supported by a suitable and sufficient Fire Risk Assessment and a clear understanding of how the building is managed in practice.
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How Does a Variation Order Support a Residential Fire Alarm Strategy?
A fire alarm strategy should reflect how residents use the building, how fire risks are managed, and how occupants are expected to respond in the event of a fire.
Where a Fire Risk Assessment recommends a variation order, the objective is not simply to avoid upgrading the fire alarm system. Instead, it is to determine whether a different fire alarm strategy provides a more proportionate and technically appropriate solution.
This may include reviewing:
- The category of the existing fire alarm system
- Automatic fire detection coverage
- The building’s evacuation strategy
- Compartmentation and passive fire protection
- Building management arrangements
- Occupancy risks and resident profile
A well-developed residential fire alarm strategy should balance life safety, practical building management, and compliance with current fire safety legislation.
Does a Variation Order Mean a Fire Alarm Upgrade Is No Longer Required?
A Fire Alarm Variation Order does not remove the need to maintain appropriate fire safety measures, nor does it override the findings of a Fire Risk Assessment. Instead, it provides a structured, risk-based justification where an alternative approach to standard guidance is considered appropriate.
In some cases, a variation order may support targeted improvements rather than a full fire alarm upgrade. In others, the assessment may conclude that upgrading the fire alarm system remains the most appropriate solution.
The outcome will depend on the building, the identified fire risks, and the overall fire safety strategy.
Fire Alarm Compliance in Residential Buildings
Responsible Persons must ensure fire alarm systems not only operate correctly but also remain appropriate for the buildings they protect.
This is particularly important for:
- Blocks of flats
- Houses in Multiple Occupation (HMOs)
- Higher-risk residential buildings
- Mixed-use developments
- Supported housing schemes
As buildings change over time, fire alarm strategies may also need to evolve to ensure they continue to provide appropriate protection for residents.
What Are the Legal Considerations?
Legislation and industry guidance influence how fire alarm strategies are developed, reviewed, and justified within residential buildings.
England and Wales
Relevant legislation includes:
- Regulatory Reform (Fire Safety) Order 2005
- Fire Safety Act 2021
- Building Safety Act 2022
- Fire Safety (England) Regulations 2022
Under the Regulatory Reform (Fire Safety) Order 2005, Responsible Persons must ensure appropriate fire precautions are in place where the legislation applies. Fire alarm strategies and any proposed variations should be supported by a suitable and sufficient Fire Risk Assessment and developed with reference to BS 5839.
Scotland
Fire safety duties in Scotland are governed by:
Although the legislative framework differs from England and Wales, duty holders must still assess fire risks, maintain appropriate fire safety measures, and ensure fire alarm arrangements remain suitable for the building.
Any alternative fire alarm strategy should be supported by a documented, risk-based assessment that reflects the building’s occupancy, management arrangements, and fire risks.
What Happens After a Variation Order Is Recommended?
A Fire Alarm Variation Order provides Responsible Persons with the technical evidence needed to make informed compliance decisions.
Following the recommendation, organisations will typically:
- Review the findings alongside their Fire Risk Assessment
- Consider the proposed fire alarm strategy
- Consult relevant stakeholders where appropriate
- Plan any agreed improvements or system modifications
- Maintain documentation supporting the chosen approach
This structured process helps organisations demonstrate that fire alarm decisions have been made using a proportionate, risk-based methodology rather than relying solely on prescriptive guidance.
Fire Alarm Strategy and Variation Orders for Residential Portfolios
Where a Fire Risk Assessment recommends a Fire Alarm Variation Order, understanding the reasons behind that recommendation is essential before committing to significant fire alarm upgrades.
If you are responsible for fire safety compliance across a residential portfolio and need a trusted provider, Osterna can help.
We work with housing associations, managing agents, and large private landlords across the UK, providing Fire Risk Assessments, Fire Alarm Strategy and Variation Orders, fire door inspections, asset testing, and wider building compliance services.
Get in touch with the Osterna team today.
Frequently Asked Questions
A Fire Alarm Variation Order is a formal document that provides a risk-based justification for adopting an alternative approach to standard fire alarm guidance, typically BS 5839, where a different solution is considered more appropriate for the premises. Its purpose is to help reduce the risk to occupants while supporting a proportionate fire alarm strategy.
A Fire Alarm Variation Order should be prepared by a competent fire safety professional with experience in residential fire alarm strategies, Fire Risk Assessments, and the application of BS 5839 guidance. Organisations should appoint a suitably qualified specialist to carry out the assessment and prepare the supporting documentation.
Variation orders provide documented technical justification for fire alarm decisions, helping Responsible Persons demonstrate that their fire alarm strategy is proportionate, risk-based, and supported by appropriate evidence. They also provide an auditable record of the responsibility for fire alarm decisions and the reasoning behind them.
Fire Alarm Variation Orders help organisations review whether proposed fire alarm upgrades are proportionate to the risks identified. By considering the building’s fire alarm strategy, means of escape, and evacuation routes, they can identify alternative solutions that maintain safety without unnecessary expenditure.
Yes. Fire alarm strategies should be reviewed regularly, particularly where there are significant changes to the building, its occupancy, or the findings of a Fire Risk Assessment. This helps ensure the documented variation remains appropriate over time.
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