2026-09-30 · HawkSwift Ltd

Fire Safety for Self-Storage Facilities: Legal Duties in the UK

Self-storage is one of the fastest-growing commercial property sectors in the UK, but its fire-safety profile is unlike a standard office or warehouse. Large open floorplates, high fire loads from stored customer goods, unsupervised 24-hour access, and limited compartmentation create risks that demand a robust approach.

If you operate, manage or own a self-storage facility, this guide explains your legal duties under the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005), the Fire Safety Act 2021, and the Fire Safety (England) Regulations 2022 — and what a suitable and sufficient fire risk assessment looks like for your premises.

This is general guidance, not formal legal advice. Book a HawkSwift fire risk assessment for a site-specific report.

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Who Is the Responsible Person for a Self-Storage Facility?

Under Article 3 of the RRO 2005, the "responsible person" is the person who has control of the premises, or a person who has been delegated responsibility for fire safety. For self-storage sites, this is usually:

The facility owner or freeholder
The operating company or management firm
A designated site manager who controls day-to-day operations

Where the facility is part of a larger mixed-use building, the responsible person for the common parts (shared corridors, escape routes, fire alarm systems) may be the building owner or management company, while the storage operator is responsible within their demised area. Article 5(3) of the RRO 2005 requires co-operation and co-ordination between multiple responsible persons in shared premises — you must have a formal agreement on how fire safety is managed across the site.

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What the Law Requires

Regulatory Reform (Fire Safety) Order 2005 — Core Duties

| Article | Duty | How It Applies to Self-Storage | |---|---|---| | Art. 9 | Carry out a suitable and sufficient fire risk assessment | Must cover all areas: storage floors, reception, offices, plant rooms, external yard | | Art. 11 | Record significant findings (if ≥5 employees or licensed) | Must include fire risks, actions taken, and who is at risk | | Art. 14 | Ensure safe means of escape | Escape routes must be clear, adequately lit, and signed throughout the facility | | Art. 17 | Maintain fire-safety equipment and facilities | Weekly alarm tests, monthly emergency lighting checks, annual extinguisher servicing | | Art. 21 | Provide staff fire-safety training | Every employee must know the evacuation plan, fire-fighting equipment locations, and their specific duties |

Fire Safety Act 2021

The Fire Safety Act 2021 amended the RRO 2005 to clarify that the responsible person for multi-occupied residential buildings must also manage the fire safety of the building structure — including external walls, flat entrance doors, and common parts. For self-storage facilities in mixed-use buildings that include residential floors above, this directly affects your duties in the common areas.

Fire Safety (England) Regulations 2022

These regulations introduced specific duties for high-rise residential buildings (over 18 metres or 7+ storeys). If your self-storage facility occupies the ground or lower floors of a high-rise residential building, you must co-operate with the building's responsible person on:

Providing fire-safety information to fire and rescue services (Regulation 5)
Ensuring floor plans and fire-door checks are up to date (Regulation 10)

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Key Fire-Safety Risks Specific to Self-Storage

1. Fire Loading and Combustible Storage

Self-storage units often contain furniture, mattresses, cardboard, electrical items, cleaning chemicals, and other combustible goods. When aggregated across a large floorplate, the total fire load can exceed what the building's structure and fire-resistance ratings were designed for.

What to do:

Restrict hazardous goods in tenancy agreements — ban flammable liquids, LPG cylinders, oxidisers, and fireworks explicitly
Impose a weight and volume limit per unit to prevent excessive fire loading
Conduct periodic visual inspections of units (with customer notice) to check for prohibited items
Keep gangways and corridors at least 1.2 metres wide — never allow storage in escape routes

2. Compartmentation and Fire Separation

Self-storage facilities typically use wire-mesh or perforated-metal partitions, which do not provide the fire resistance required by Approved Document B of the Building Regulations. The result: fire and smoke can spread rapidly across the floor.

What to do:

Install fire-resisting partitions (30-60 minutes fire rating, as identified by your fire risk assessment) between individual units
Ensure any mezzanine floors have proper fire separation from the main storage area
Seal all service penetrations (cables, pipes, ducts) through compartment walls with fire-stopping materials
Commission a compartmentation survey as part of your FRA — BS 9999:2017 and PAS 79 provide the assessment framework

3. Means of Escape

Large open storage floors with limited exit points can create excessive travel distances. Under Approved Document B, travel distance in a single direction should not exceed 18 metres in normal risk, or 60 metres where alternative escape routes are available. In self-storage, the maze-like layout of unit rows can confuse visitors unfamiliar with the building.

What to do:

Mark all escape routes with photoluminescent signage
Install emergency lighting to BS 5266-1 covering every escape route, final exit, and change of direction
Ensure maximum travel distance is verified in your fire risk assessment
Provide a site-specific emergency plan displayed at reception, main exits, and staff areas

4. Unsupervised Access and Arson Risk

Self-storage facilities often allow 24-hour tenant access with limited on-site supervision. This creates a risk of arson, unauthorised storage of hazardous materials, and blocked escape routes.

What to do:

Install CCTV covering all storage floors and entrances
Restrict access to tenants only — use PIN-code or fob entry with audit trails
Ensure security patrols or remote monitoring outside operating hours
Lock all external plant rooms, electrical cupboards, and service risers

5. Fire Detection and Alarm Systems

A standard manual alarm (Category M) is insufficient for a self-storage facility where occupants may be alone and unsupervised. BS 5839-1 recommends at least a Category L2 or L3 automatic fire-detection system in storage premises, covering escape routes, high-risk areas, and storage floors.

What to do:

Install automatic smoke detection on all storage floors and escape routes
Link the alarm system to a remote receiving centre (ARC) for out-of-hours response
Test weekly under Article 17 of the RRO 2005
Record all tests in your fire-safety logbook

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The 5-Step Fire Risk Assessment for Self-Storage

A suitable and sufficient fire risk assessment follows the standard 5-step approach set out by the Home Office (formerly CLG guidance):

| Step | What It Covers in Self-Storage | |---|---| | 1 Identify fire hazards | Combustible storage, electrical equipment, heating plant, vehicles, prohibited goods | | 2 Identify people at risk | Staff, lone workers, tenants (especially those unfamiliar with the layout), contractors, fire and rescue crews | | 3 Evaluate, remove or reduce risks | Reduce fire loading, improve compartmentation, install detection, secure plant rooms | | 4 Record findings and train staff | Write your action plan, train staff on evacuation duties, issue tenant fire-safety information | | 5 Review regularly | Review at least annually, and on any significant change (new building, change of use, enforcement visit) |

Your fire risk assessment should be carried out by a competent person under Article 18 of the RRO 2005. Competence means more than basic fire-safety awareness — it requires formal training (such as NEBOSH Fire Certificate or the SFJ Awards qualification for BAFE SP205 registration), knowledge of the fire-safety legislation relevant to your premises type, and experience assessing similar facilities.

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Common Compliance Gaps We Find in Self-Storage FRAs

From our experience assessing commercial properties across the UK, the most common compliance gaps in self-storage facilities are:

1. No written fire risk assessment — despite employing 5+ staff or managing a site over 200m² 2. Inadequate compartmentation — mesh partitions without fire-resisting linings 3. Fire loading exceeds building design — nothing in tenancy agreements limiting combustible storage 4. BS 5839 alarm category too low — manual call points only, no automatic detection on storage floors 5. No emergency plan — tenants and visitors have no information on what to do in a fire 6. Staff untrained — no fire warden training, no logged drills (Article 21 duty) 7. Fire doors propped open or self-closers disabled — common where tenants want easy access

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Frequently Asked Questions

Do I legally need a fire risk assessment for my self-storage facility? Yes. Under Article 9 of the Regulatory Reform (Fire Safety) Order 2005, every non-domestic premises must have a suitable and sufficient fire risk assessment. Self-storage facilities are non-domestic premises and are subject to the same duties as offices, shops and warehouses.

Can a self-storage tenant do their own fire risk assessment? The duty sits with the responsible person — that is, the operator or owner of the facility. A tenant's own assessment does not discharge the operator's legal duty under Article 9. However, tenants should be given fire-safety information and may have duties under their lease (e.g. not storing prohibited goods).

What fire rating do self-storage partition walls need? Your fire risk assessment should determine the required fire-resistance duration (usually 30 or 60 minutes) based on the building's fire strategy, occupancy, and proximity to escape routes. Generally, wire-mesh alone is not acceptable — partitions must be lined with fire-resisting board and any gaps fire-stopped.

Are tenants responsible for their own fire safety inside their unit? Under the RRO 2005, the facility operator retains overall responsibility. However, the lease or licence agreement should place a duty on tenants not to store hazardous goods, block gangways, or disable fire-safety equipment. The operator must enforce these terms through regular inspections.

How often should a self-storage fire risk assessment be reviewed? At least annually (Article 9(3)). You should also review whenever there is a significant change — a new building extension, change of use, introduction of electric vehicle charging points, a fire incident, or an enforcement notice from the Fire and Rescue Service.

Book your self-storage fire risk assessment

*This article is general guidance and not formal legal advice. The fire-safety duties described refer to England and Wales; separate legislation applies in Scotland (Fire (Scotland) Act 2005) and Northern Ireland (Fire Safety Regulations (Northern Ireland) 2010).*

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