The procedure to evaluate fire safety of alternative ship design solutions, described in MSC/Circ.1002, has been found insufficient for novel and large scopes. In this paper, it is analysed with regards to function and applicability as a risk-based assessment procedure. Deficiencies are addressed based on risk assessment research and involvement in over a dozen performed assessments. Clarified are inconsistencies in the fire safety regulations, which must be considered particularly during identification of hazards. It is also suggested that affected safety functions are evaluated separately if possible and that the assessment sophistication is adapted to the scope of introduced hazards; four levels to perform parts of or the whole assessment are proposed.