Turn up for a fire safety inspection with nobody on site who can explain who is trained to sweep the building, and the enforcing officer will not accept "we're planning to sort it" as an answer. Under the Regulatory Reform (Fire Safety) Order 2005 (RRO 2005), that gap can lead straight to an enforcement notice, and if a real fire happens before you close it, to a prosecution with no small-business exemption to hide behind.
Fire marshals (sometimes called fire wardens) are the people in your workplace trained to lead an evacuation: checking rooms, closing doors, guiding people to the assembly point and liaising with the fire service. Plenty of employers assume a laminated notice on the wall covers this. It does not.
What the law actually requires
The RRO 2005 does not use the words "fire marshal" anywhere in its text. What it requires, under Article 21, is that the responsible person provides employees with adequate fire safety training, and under Article 15, that the responsible person nominates enough competent people to implement the evacuation procedures set out in the fire risk assessment.
In practice, "competent people" means trained fire marshals. The Order does not fix a number, a training syllabus or a refresher interval. It leaves all three to be worked out from your fire risk assessment, which since section 156 of the Building Safety Act 2022 came into force on 1 October 2023 must be recorded in writing by every responsible person, whatever the size of the business. The old exemption for employers with fewer than five staff no longer applies.
That matters for training too. If your written fire risk assessment identifies marshals as part of your evacuation plan, and you have not trained anyone, or the training has lapsed, the assessment and the actual state of the workplace no longer match. That mismatch is exactly what an inspecting officer from the fire and rescue authority is looking for.
How many fire marshals do you need
There is no statutory ratio of marshals to staff. The right number depends on the layout and size of your premises, how many people are on site at any one time, whether you operate across multiple floors or shifts, and what your fire risk assessment concludes is needed to clear the building safely. A single-storey shop with six staff on one shift needs a different answer to a three-floor office running a 24-hour rota.
The working rule most fire risk assessors apply is that every floor, and every shift, needs at least one trained marshal who is actually present, plus a backup in case that person is on leave or off sick on the day. A small ground-floor office of eight people might manage with one marshal and one backup. A three-floor building running an early shift, a late shift and a weekend skeleton crew could need six or more trained people to guarantee cover across every combination of floor and shift pattern. We cover the detail of getting this number right in how many fire wardens your workplace actually needs.
Do not count on the same two or three people every time. Staff go on holiday, change shifts or leave the business, and a marshal rota with no depth collapses the first time someone is off sick during an actual evacuation.
What fire marshal training must cover
A generic online video is not enough on its own. Adequate training under Article 21 needs to be specific to your premises and the risks identified in your fire risk assessment. At minimum it should cover:
- How to raise the alarm and who to call
- How to conduct a systematic sweep of an assigned area, including toilets, store rooms and areas out of sight of the main floor
- How to use the extinguishers provided, without putting themselves at risk to tackle a fire that has taken hold
- How to assist anyone who needs extra help evacuating, including checking any personal emergency evacuation plans
- Where the assembly point is and how to take a headcount against a visitor and staff log
- How to liaise with the fire and rescue service on arrival, including confirming whether the building is clear
Training that skips the site-specific detail, the layout of your actual building, your actual fire alarm type and your actual evacuation routes, will not stand up well if it is ever tested by a real incident or a post-incident investigation.
How often to retrain
Article 21 does not set a fixed refresher period, and be wary of anyone who tells you the law mandates an exact number of months. What it does require is that training is repeated periodically and updated whenever risks change: a refurbishment, a new fire alarm system, a change of layout, or new work equipment all trigger a need to retrain.
In the absence of a legal figure, annual refresher training is the practice most fire and rescue authorities expect to see, and it is what most insurers and accreditation schemes look for too. Higher-risk premises, or those with high staff turnover, often refresh more frequently, sometimes every six months, simply because so few of the originally trained marshals are still around a year later.
Records and proof
Keep a simple log: who was trained, by whom, when, and what the training covered. If your fire risk assessment says you have four trained marshals across two floors and an inspector asks to see the evidence, you need to be able to produce it in minutes, not go looking for an email from three years ago.
This record sits alongside your written fire risk assessment, your fire alarm testing log and your fire extinguisher service records as the paperwork a fire and rescue authority will ask for first. Gaps in any one of them tend to prompt a much closer look at everything else.
Common mistakes worth fixing now
The most frequent problem is not a lack of training, it is training that has gone stale without anyone noticing. A marshal trained four years ago at a previous employer's premises, or before your office moved floors, is not trained for the building you occupy today.
The second is treating fire marshal training and first aid training as interchangeable because the same external provider runs both courses on the same day. They cover different competencies, and a certificate for one does not satisfy the Article 21 duty for the other.
The third is appointing marshals who are rarely on site: a manager who works from home three days a week, or someone on a fixed-term contract who has since left. Check your marshal list against your actual staff rota at least twice a year, not just when a new starter reminds you the list is out of date.
Fire wardens for visitors and contractors
Article 22 of the RRO 2005 extends some duties to non-employees on your premises, including contractors and visitors. Your marshals should know how to account for anyone signed in that day, not just permanent staff, which means your visitor log and your evacuation headcount procedure need to talk to each other.
Next steps
Start from the fire risk assessment, not the training course. Until you know how many people need to be trained, on which floors, and to cover what evacuation routes, any training you book is a guess. FRASafe's small business fire risk assessment walks you through every area the RRO 2005 requires, completed online in 30 to 45 minutes for £45, and gives you the clear evacuation plan and marshal numbers your training needs to be built around. See our free fire risk assessment template for what a properly documented assessment should include before you book anyone onto a course.