That's how I understood it, Val and, having served (some years ago) in an EH Dept considered an EHO to be an official representative of a responsible authority who could make the necessary representations.
I must admit to having endeavoured to consider fire safety as well as other guidance relating to occupancy (including public order) and applied whichever were the more demanding standards . This approach was also taken for numerous events held in the local authority's premises whenever the activity was not licensable but required permission to take place. I wonder to what extent such events are being addressed in that way now - particularly if FRSs are not being informed or, perhaps, are not able to respond by taking the view that it's simply down to the RP and the local authority are taking a similar approach?
I recognise the RRO intention to establish a clear responsibility upon RPs but, when it comes to public events, in my experience, you are often dealing with well-meaning amateurs, political activists, local residents, evangelists, actors, youth leaders, etc, etc with little, if any, technical knowledge of fire and other aspects of health and safety and who are quite taken up with the content of the event rather than its potential consequences. I've spent many an 'opening night' arranging chairs and getting them tied together, sending people off to get fire extinguishers and telling them where to put them, getting electric and other cables re-routed, etc, etc. This may well 'go against the grain' of today's thinking but somehow the thought of what might happen otherwise was of greater concern. I know they ought to go and get guidance from competent persons but will they? and, if not, laying the blame at their door will do little for the injured or families of the dead.