Not automatically. Since the Fire Safety Act 2021, the fire risk assessment for any block of flats must consider the external walls, whatever the height. A specialist appraisal using PAS 9980 is usually needed only when the fire risk assessor identifies concerns about the wall system, such as combustible materials or an unknown construction.
External walls are part of every fire risk assessment
The Fire Safety Act 2021 confirmed that, in a building with two or more sets of domestic premises, the Fire Safety Order covers the structure and external walls, including windows, balconies and cladding. Your fire risk assessment must consider them, whatever the height of the building.
When a PAS 9980 appraisal is needed
A fire risk appraisal of external walls (FRAEW) using PAS 9980 is a specialist assessment. It is usually triggered when the fire risk assessor identifies concerns, for example:
- combustible cladding or insulation
- a wall construction that cannot be identified from records or inspection
- signs that a more detailed investigation is needed
Government guidance makes clear that an appraisal can be needed for blocks of any height, but that buildings with traditional brick or masonry walls are generally unlikely to need one.
What to do
Start with a fire risk assessment that properly considers the external walls. If concerns are identified, the assessor will recommend a specialist appraisal by a suitably qualified professional, and the responsible person should act on that recommendation.
This answer is general guidance on the law in England and is not a substitute for advice on your specific premises.