Dan Quinn, director of fire at Frankham Risk Management Services, part of the Frankham Group, draws upon his 25-year career in the fire and rescue service to delve into Approved Document B
Arguing that the biggest shift is how fire safety guidance is now created, he discusses what these changes now require of developers, designers and building owners.
As of 30 September, new blocks of flats with a storey 18 metres or more above ground level should be served by more than one common stair. Although this change in guidance may seem like a risk, the real issue is finding out too late that your scheme sits on the wrong side of it.
The story so far
At operational fire stations in the early 2000s, changes to fire safety guidance felt like something that happened somewhere else. When the amended pages arrived, often with HB pencil in the margin, there was little transparency about how decisions were made, who argued for them, or what evidence backed the amendment.
That’s no longer the case. Ahead of the changes that took effect on 30 September, a public consultation was held that lasted several months and drew 285 responses, ultimately resulting in an amendment published in March 2024. That in itself is progress – the industry was consulted, the threshold was moved in response to the evidence, and the market was given two and a half years to adjust.
This doesn’t make existing single-stair buildings inherently unsafe. As long as they were built to relevant standards, are well maintained and properly managed, the change isn’t retrospective.
Where do you stand?
We are currently in a period of transition – if your scheme is ‘sufficiently progressed’, then previous guidance can still apply. The risk now is knowing which side of this you land on. If your residential scheme is approaching the 18-metre threshold, I would ask yourself three questions.
First, where does it stand against the transitional test? The trigger is the building control submission and progress on site – not planning permission. A consented scheme without a building control application submitted by 30 September is designed to the new guidance.
Second, can it realistically meet the “sufficiently progressed” test within 18 months? If funding, procurement or regulatory approval could push foundations beyond that window, plan for the second stair now – rather than redesigning later.
And finally, what does a second stair do to the rest of the design? The core layout, net-to-gross, smoke control, firefighting access, and the fire strategy all move with it. That is a question for the whole design team, not the fire consultant alone.
Approved Document B sets out one way of meeting the functional requirements of Part B of Schedule 1 to the Building Regulations 2010. It is not a checklist, and the Grenfell Tower Inquiry exposed the consequences of treating guidance as if it were.
That cuts both ways. A scheme can follow the guidance line by line and still be poorly thought through. Equally, a properly engineered alternative that demonstrates an equivalent or better level of safety remains a legitimate route. What has changed is the scrutiny. Expect any departure from the guidance to be tested hard, and make sure the reasoning is written down, evidenced and owned.
Continuous progress
Although 30 September created no new legal duty for housing providers and building owners of existing single-stair blocks, it will prompt questions from residents, boards, lenders and insurers.
The answer isn’t a reflex programme of works, but rather a suitable and sufficient fire risk assessment that reflects the building as it really is. It’s an evacuation strategy, the condition of compartmentation and fire doors, smoke control, and how the fire and rescue service would fight a fire there. If your assessment cannot answer ‘is our single-stair building safe?’ clearly and with evidence, that is the gap to close.
This amendment isn’t the end point. In September 2029, all remaining references to BS 476 will be removed from Approved Document B, and a wider review of the guidance is still ongoing. External walls, evacuation lifts, balconies, and alarm standards in specialised housing are all under consultation.
Schemes being designed today will be completing into a further evolved landscape. We need to consider the overall direction of travel, not just the guidance in force on the day of submission.
From pencil to process
It’s no secret what happens when guidance is treated as a box to tick. A system that consults, publishes its reasoning and gives industry time to prepare is a real step forward. But processes only make buildings safer if the people using the guidance engage early, understand the reasoning behind it and apply judgement to the building in front of them. That is the standard we should hold ourselves to, well before the next deadline.
