Without going into the principles of the procedural guidance it is much more basic than that, in the words of a fire safety consultant, formulating a strategy in support of a poorly designed building ;
" I am not here to provide fire precautions that are achievable, I am here to atain building regs. approval"
There is a difference in the two, particularly when clients can shop around for building control bodies, to provide a cost effective ! solution to approval.
Following the introduction of the RRfsO, it is now up to FRS to grasp the nettle and issue 'enforcement notices or alterations notices' and enforce them robustly, this should send a message to developers/and designers etc. to build buildings that are safe with flexibility in use, as part of the design brief. Also certain fire safety consultants are using creative accountancy to atain building regs approval.
Risk assessment should not be part of Building regs. unless they can be specific at the time of building as to the use and owners etc. as many designers etc. state they have risk assessed the fire strategy before they know the occupier or specific use, they use generic titles that suit their purpose of providing cheap building costs and unsatisfactory buildings. I am not an advocate of 'prescriptive' codes but a believer in honesty and integrity ( I know how naive) . If designers,consultants and now building control bodies, did not have a financial incentive there would not be the problems now appearing.
Sorry for that rant !!