United Kingdom

Accounting for everyone in a fire evacuation.

The Fire Safety Order requires evacuation procedures and, since October 2023, a recorded risk assessment in every case. It does not mention roll call or visitor logs once. Here is what it actually asks for, and why visitors and contractors are where the procedure breaks.

What the Order actually says

The Regulatory Reform (Fire Safety) Order 2005 is the law that applies to workplaces in England and Wales. It puts duties on a “responsible person”, usually the employer or whoever controls the premises. Two articles matter for evacuation.

Article 9: the assessment must now be recorded, in every case

Article 9 requires a suitable and sufficient fire risk assessment. Since 1 October 2023, when section 156 of the Building Safety Act 2022 took effect, that assessment and the fire safety arrangements must be recorded in all cases. The old threshold that only caught employers with five or more staff is gone.

What has to be recorded includes the findings, the measures taken or to be taken, and any group of people identified as being especially at risk.

Article 15: procedures, and competent persons to run them

Article 15 requires procedures to be established for serious and imminent danger, including safety drills, and requires a sufficient number of competent persons to be nominated to implement those evacuation procedures.

Note the language. The Order says competent persons, not fire marshal or fire warden. Those are the terms everyone uses in practice, and neither appears in the legislation.

What the Order does not say

It is worth being precise, because a lot of software marketing is not. The Fire Safety Order contains no requirement for a visitor log and no requirement for a roll call. Neither phrase appears anywhere in it.

Roll call is the conventional method fire risk assessors use to discharge articles 9 and 15. It is how organisations demonstrate they can account for people, not a clause you can cite. Anyone telling you the law mandates a visitor management system is overstating it.

The obligation that does bite is simpler and harder: your procedures have to work for everyone on the premises. Not just the people on your payroll.

Why visitors and contractors are the hard part

Most organisations can account for employees. There is a list, the line managers know their teams, and the numbers roughly work. The gap is everyone else.

Visitors who signed a paper book that is still on the reception desk, inside the building you have just evacuated.
Contractors who arrived at a goods entrance, or who were inducted three months ago and nobody logged today.
People who left without signing out, who will be searched for by a fire marshal standing in the car park.
Anyone in a part of the building nobody thought to sweep, which is where the article 9 duty to identify people especially at risk becomes concrete.

A roll call that says 74 people are missing when 71 of them drove home at five is worse than no roll call, because it sends someone back into a building for no reason.

What a defensible procedure looks like

Everyone on site is on one list, employees, visitors, contractors and deliveries, and the list is current rather than assembled after the alarm.
The list is reachable from outside the building. A record only available on a machine at reception is not a record you have during an evacuation.
Signing out is as deliberate as signing in, or the list slowly fills with people who are not there.
Each assembly point can see who it expects, so a marshal is checking a list rather than counting heads.
The drill produces its own record, because article 9 requires the arrangements to be recorded and a drill nobody wrote up is hard to evidence.

What about Martyn’s Law?

The Terrorism (Protection of Premises) Act 2025 received Royal Assent on 3 April 2025. It is widely marketed as a reason to buy visitor management software. It is worth knowing what it actually says before you act on that.

It is not in force. Only administrative sections have been commenced. The duties in sections 5 and 6 have not been. Enforcement is expected in Spring 2027, and the government has described this as an implementation period of at least 24 months rather than a fixed statutory date, so it may move.
Offices are not in scope. The premises uses listed in Schedule 1 do not include offices, workplaces or commercial business premises. It is aimed at publicly accessible venues.
Standard tier requires no purchases. The Home Office has said there is no requirement to put in place or purchase physical measures, and costed standard tier compliance at around GBP 330 a year, which it describes as management and staff time rather than cash expenditure.
It does not require a visitor log or a headcount. Section 5 is written as procedures directed at individuals as a group, never as identifying or tracking them.

There is one genuine connection, and it applies to enhanced tier premises only, meaning capacity of 800 or more. Section 6 requires the responsible person to consider measures relating to the movement of individuals into, out of and within the premises. If you run a venue at that scale, that is a real assessment to make. If you run an office, Martyn’s Law is not your obligation and the Fire Safety Order is.

Scotland and Northern Ireland

The Fire Safety Order covers England and Wales. Scotland operates under the Fire (Scotland) Act 2005 and Northern Ireland under its own regime. The duty to account for people is broadly comparable, but if you are writing a policy for a multi-site UK estate, check the relevant regime rather than assuming the Order applies everywhere.

Where BeckonDesk fits

BeckonDesk keeps one live list of everyone on site: employees, visitors, contractors and deliveries, signed in at a kiosk or pre-registered before they arrive. When an evacuation starts, that list is on any phone, so a fire marshal at the assembly point is checking names rather than counting heads, and people can be marked safe from the car park with the count updating for everyone at once.

To be clear about what that is and is not: it makes your procedure workable and produces a record you can point at. It does not make you compliant with the Fire Safety Order. The risk assessment, the competent persons and the arrangements remain the responsible person’s duty.

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