22 Jan 2026

Should your O&M manual have a dedicated separate Fire Safety section?

Fire safety regulation in the UK does not operate under a single, unified system. Instead, it is governed by a series of devolved building safety regimes across England, Wales, Scotland, and Northern Ireland. This makes the provision of clear, compliant handover information including the Operation and Maintenance (O&M) manual increasingly important.

As regulatory expectations continue to evolve, particularly around building safety and lifecycle information, a key question emerges: should fire safety information be embedded within the O&M manual, or provided as a clearly defined, separate fire safety section or pack?


England and Wales

In England, the regulatory landscape is now largely shaped by the Building Safety Act 2022, with Wales broadly aligning to this approach through its own Building Safety Programme, subject to devolved amendments and timescales. The Act applies primarily to Higher-Risk Buildings, defined as residential buildings that are 18 metres or more in height or seven storeys and above. Wales has adopted a similar framework but applies it to a wider range of buildings, with thresholds starting at 11 metres or five storeys, capturing what are often referred to as medium-risk residential buildings.

For buildings within scope, there is a requirement to maintain a ‘Golden Thread’ of building safety information throughout the building’s lifecycle. This includes clear, accurate and accessible fire safety information that can be relied upon by duty holders and regulators.

Crucially, UK building regulations require that sufficient fire safety information be provided to the Responsible Person no later than completion, to enable the building to be operated and maintained safely. This requirement applies across all building types where Building Regulations apply. Traditionally, this information has been embedded within the wider O&M manual. In practice, this can make fire safety data difficult to identify, review and demonstrate as complete at handover.

Separating fire safety information into a clearly defined section at the point of O&M collation can significantly improve transparency. It enables key stakeholders to review and confirm the completeness of fire safety information at handover, while still allowing it to sit alongside the full O&M set where required. COGNICA’s Fire Safety Content Separation service supports this by identifying and separating fire and structural safety information at source, ensuring a smooth, consistent, and well-controlled handover process.


Scotland

Scotland operates under a different regulatory model. The Building (Scotland) Amendment Regulations 2025, which introduce a targeted package of fire safety changes, are scheduled to come into force on 06/04/2026.

Unlike England and Wales, Scotland does not operate a Golden Thread framework. There is no single, prescribed format for fire safety handover documentation or O&M manuals. Instead, the Scottish system takes a standards-based, evidence-led approach.

To obtain a completion certificate, verifiers expect clear evidence that fire safety measures are installed and compliant. This may include, where applicable:

      • Fire detection and alarm systems
      • Automatic fire suppression systems
      • Fire-resisting construction and compartmentation
      • Means of escape provisions

    This evidence often forms part of the O&M documentation, but the regulations do not mandate how it should be structured or presented. As a result, embedding fire safety information within the standard O&M format is acceptable for Scottish projects, provided the information is clear, complete, and usable.


    Northern Ireland

    Northern Ireland has already implemented significant changes through the Building (Amendment) Regulations (Northern Ireland) 2024, which came into effect on 06/05/2025. These amendments introduce changes to Part E (Fire Safety) and to Regulation 8, which relates to material change of use.

    Key elements of the updated regime include:

      • New requirements for automatic fire suppression systems in certain buildings
      • Enhanced fire safety information requirements
      • The introduction of restrictions on combustible materials in specific building types

    Northern Ireland’s approach places a strong emphasis on:

      • Fire suppression strategies (where required), including inspection and servicing regimes
      • Clear fire safety information for building owners and occupants

        These requirements have a direct impact on handover packs and O&M content. Under Technical Booklet E, there is an explicit expectation that information necessary for the safe operation and maintenance of fire safety measures is provided to the building owner.

        This typically includes information relating to:

          • Fire detection and alarm systems
          • Automatic fire suppression systems
          • Smoke control systems
          • Emergency lighting
          • Fire-resisting construction and compartmentation
          • Means of escape assumptions

            While there is no mandated O&M format in Northern Ireland, the principle of providing clear, usable fire safety information is firmly embedded. Collation within a standard O&M structure is therefore acceptable, provided the required fire safety content is clearly identifiable.


            So, should Fire Safety be a separate section?

            Across all UK jurisdictions, one principle is consistent: fire safety information must be clear, complete, and usable at handover. While not all regions mandate a separate fire safety manual, regulatory scrutiny is increasingly focused on the ability to identify, verify and evidence compliance.

            For many projects, particularly those subject to enhanced building safety regimes, a clearly defined fire safety section delivered alongside the O&M manual provides a practical and auditable solution. It supports compliance, reduces risk at handover, and ensures that building owners and duty holders can discharge their responsibilities with confidence.

            COGNICA delivers this through its Fire Safety Content Separation service, which identifies the key requirements of fire and structural safety information at source, helping to ensure a clear, efficient, and auditable process from start to finish.

            Contact Us for a no obligation quote and to find out more about COGNICA’s collation services, and how the O&M Manuals are evolving to meet the requirements of Fire safety regulation.