risk assessments have been needed since 1974 for all health and safety risks, specific fire safety risk assessments since 1997.
Which is why lots of places have done H&S RAs. Indeed on inspections they can readily pull out dozens of various RAs for the endless subsidiary bits of law under the HASWA, but always have trouble when it comes to fire.
Yes FRAs were technically required in 1997 but for non certified premises, which were rarely visited anyway for 9A compliance and so there was little education or enforcement, certified premises happily continued under the FPA. Very few FRAs existed at this time - I remember doing one as part of my 3rd year in Uni on placement in 96 using the rather rudimentary draft guidance that was about. Our client base 97-99 only required Fire Certificate Compliance Audits and the small number of non certified multiocc's didn't want FRAs, just H&S stuff.
99 as we know saw FRAs extended to certified premises - but the FPA was retained and in our experience most Fire Authorities clung to certification, with the odd leaflet drop being made to mention the existence of the requirements for FRA, and few occupiers seemed to be doing FRAs and even less fire authorities enforced it (most prosecutions & notices we saw reported or were involved in resolving from 99 to 06 were under the FPA).
Many FRAs we did see were tick boxes or similar and showed little appreciation of what was needed and if it weren't for pre-existing (albeit outdated in some premises)measures required under a certificate standards in premises would have been dangerous with little compartmentation , minimal EL, poor fire warning but lots and lots of extinguishers.
The fact that the RRO has finally destroyed the safety net of fire authority led specification and certification will have come as a massive culture shock, especially as it is being enforced and publicised - many owner/occupiers will be bewildered and confused.