Mixed-Use Fire Safety: Clarifying Ownership and Accountability

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In the increasingly complex world of building safety regulation, fire-stopping has become one of the most critical—and most misunderstood—elements of passive fire protection. Through our work at GDA Surveying, supporting clients across commercial, residential, and mixed-use schemes, we have seen first-hand how fragmented accountability can compromise life safety and compliance.

Nowhere is this more apparent than in mixed-use buildings, where the convergence of commercial and residential space introduces a challenging mix of occupancy, risk exposure, and fragmented responsibility.

While the technical function of fire-stopping is well understood—sealing service penetrations to maintain compartmentation—the practicalities of implementing, maintaining, and managing it across mixed-tenure buildings are fraught with issues that demand serious attention from owners, occupiers, and landlords alike.

The Nature of Mixed-Use: One Building, Many Stakeholders

GDA regularly supports asset owners, landlords, and managing agents in navigating fire safety in buildings with complex stakeholder arrangements. Mixed-use buildings typically combine commercial premises (such as retail units, restaurants, or offices) at lower levels with residential accommodation above. This inherently creates multiple duty holders, such as:

  • The freeholder or superior landlord
  • Commercial tenants
  • Residential leaseholders or a Residents’ Management Company (RMC)
  • Managing agents
  • The Principal Accountable Person (PAP) under the Building Safety Act 2022

Each of these parties may control different parts of the building, yet fire does not respect those boundaries. Poor coordination or unclear responsibilities can result in significant fire safety failings.

Where Fire Safety Measures Often Fail

In many buildings, service penetrations pass between commercial and residential zones—whether for HVAC systems, cabling, or plumbing. It’s not uncommon for:

  • Contractors to make new penetrations without reinstating fire-stopping
  • Fire-stopping to be compromised by historic or undocumented works
  • Different parts of the building to be governed by separate leases, with no one clearly responsible for fire-stopping in shared areas or vertical risers
  • Fire safety information to be outdated or non-existent

We’ve found that breaches often go unnoticed, especially where leases are silent on fire-stopping responsibilities or where managing agents are unaware of concealed areas.

Who Is Accountable for Fire Safety?

The Principal Accountable Person (PAP) and Accountable Persons (APs) bear the legal duty to assess and mitigate the risk of fire spread through the building structure under the Building Safety Act 2022. That includes maintaining effective compartmentation and fire-stopping between commercial and residential areas.

However, commercial tenants may carry out internal fit-outs involving mechanical and electrical installations that breach fire compartments. Residential occupiers may be unaware that their safety is affected by commercial activity below. Landlords and managing agents may be unaware of the full condition of fire barriers, particularly in concealed voids.

The result? Everyone shares the risk, but no one takes full ownership—until it’s too late.

GDA’s Approach to Managing Fire Safety in Mixed-Use Assets

GDA Surveying works with commercial property owners and their managing agents to take a proactive and practical approach to fire-stopping in complex buildings. Our typical support includes:

  • Intrusive fire-stopping inspections, especially at the interface between commercial and residential areas
  • Reviewing all leases and service agreements to clarify who is responsible for which areas of the fire safety system
  • Implementing a Permit to Work system for any contractors carrying out penetrative work
  • Maintaining an up-to-date fire-stopping register as part of the building’s “golden thread” of safety information
  • Ensuring fire risk assessments (and FRAEWs, where relevant) specifically address the complexity of mixed-use conditions
  • Engaging tenants—both residential and commercial—in fire safety awareness and cooperation

Final Thoughts

Fire-stopping is not just a technical fix—it’s a matter of legal liability, operational risk, and life safety. In mixed-use buildings, the interface between commercial and residential space is one of the most vulnerable and often overlooked aspects of fire strategy.

For owners, occupiers, and landlords, the message is clear: fire-stopping is everyone’s business. But without clear governance, proactive inspection, and proper coordination, it can easily fall through the gaps—sometimes with catastrophic consequences.

GDA Surveying is a RICS-registered firm, consisting of highly experienced chartered surveyors, providing expert advice and project support. Our dedication to delivering personalised solutions—and a strong commitment to quality and exceptional customer service—sets us apart.

Need support with fire-stopping, project delivery, or Building Safety Act compliance?
Get in touch to see how GDA Surveying can help you meet your statutory obligations

We strive to excel in everything we do, and ensure we provide expert advice and guidance at the right time to help our clients achieve their goals.

For more information on the above or to discuss any other requirements please get in touch.

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