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High risk residential: fire safety measures must go in at the outset

Adrian Dobson

Adrian Dobson looks at the lessons from Planning Gateway One and reports on RIBA efforts to maintain momentum on fire safety in high-risk residential buildings

Continuing concerns over single stair tall buildings and extended travel distances have been raised by the Building Safety Regulator, following monitoring of Planning Gateway One submissions.
Continuing concerns over single stair tall buildings and extended travel distances have been raised by the Building Safety Regulator, following monitoring of Planning Gateway One submissions. Credit: iStock

With the implementation of the Building Safety Act we look forward to a wholesale reform of the Building Regulations system in England, but for higher risk residential buildings the first piece in the jigsaw has been in place since August 2021, when Planning Gateway One was introduced. This brought in measures to ensure fire safety matters were considered at the planning stage for schemes involving a relevant high rise residential building – 18m or more in height or seven or more storeys.

Planning Gateway One fire statements must provide information about:

  • The principles, concepts and approach relating to fire safety
  • Site layout
  • Emergency vehicle access and water supplies for firefighting purposes
  • Consultation undertaken on issues relating to the fire safety of the development
  • How any policies relating to fire safety in relevant local development documents have been taken into account.

One year’s experience

In November 2022 representatives of the RIBA met the Building Safety Regulator (BSR) at the Health and Safety Executive (HSE) to be briefed in detail on findings from the first year of Planning Gateway One in operation. The feedback is that during the start-up period nearly two thirds of applications generated some or serious concerns, with a smaller percentage recommended for outright rejection.

Correct the focus

While this is disappointing, it is perhaps not entirely surprising, and indeed it is to some extent reassuring that the BSR is empowered to take appropriate action. For many proposed developments the focus still seems to be on achieving minimal compliance, with development economics, rather than a culture of building safety, apparently the overriding driver.

Availability of fire safety engineering expertise also continues to be a challenge. The Building Safety Regulator reports a decrease in the proportion of applications of concern in the last few months, but sends a clear message that successful navigation of the Planning Gateway One process requires the proper demonstration of the fire safety case – not just compliance with guidance in Approved Document B or BS9991.

For many proposed developments the focus still seems to be on achieving minimal compliance

The dominant concerns reported by the BSR relate to:

  • Means of escape – staircases, evacuation lifts and protected escape routes, and in particular concerns about single-stair tall buildings and extended travel distances
  • Firefighter access and facilities – firefighting shafts, fire appliance access and access to water
  • External fire spread – use of combustible materials (new Approved Doc B requirements which came into force in December 2022 should provide greater certainty)
  • Basements and covered car parks – separation from stairs serving upper floors.

Keeping in touch

For our part, the RIBA has committed to undertaking quarterly briefing meetings with the BSR to understand lessons learnt from implementation of the new Building Safety regime, which we can pass on to our members through our communication channels. We would like to develop best practice design exemplars working with the BSR and will be incorporating this insight into our popular ‘Building Safety Act – next steps for architects’ programme delivered via RIBA Academy, our member CPD platform. We are also publishing the new ‘RIBA Guide to the Building Safety Act’, setting out the expectations on duty holders and the implications for professional services contracts, and will shortly release an updated version of the RIBA Health and Safety Guide.

The RIBA will also issue further guidance to the RIBA Plan of Work stressing the need to base planning applications for higher risk residential buildings on a co-ordinated Stage 3 design, not on a Stage 2 basis, and for this to include a Qualitative Design Review.

We will support and reinforce the BSR’s message that single staircase designs for residential buildings over 18m should only be considered in the most exceptional circumstances, such as constrained retrofit of existing buildings. The RIBA will also continue to press for a research-based, prescriptive height threshold for a second means of escape to be incorporated in Building Regulations and British Standards. In December 2022, the National Fire Chiefs Council  (NFCC) called on the government to ensure that all new high-rise residential buildings over 18m, or seven storeys, have more than one fire escape staircase, commenting that: ‘In the event of a fire, a correctly designed second staircase removes the risk of a single point of failure, buying critical time for firefighting activities and providing residents with multiple escape routes.’ England remains an international outlier, with countries such as the US, Canada and Australia all having prescribed height limits.

On 23 December 2023 the government announced a new consultation, closing on 17 March 2023, on potential amendments to Approved Document B, including proposals to introduce a threshold height  for residential buildings above which they should be designed and built with 2 staircases and sprinkler requirements in new care homes.

Meet the challenge

When Dame Judith Hackitt called for a culture shift in relation to building safety, the challenge she set the architectural profession was to address key areas – at the earliest design stages – with fire engineering professionals. Without this essential move, the fundamentals of means of escape, firefighter access and facilities, and the separation of high fire risk areas, could become locked in. We can’t afford to simply rely on fire engineering to ‘fix’ or find solutions for in-built design constraints. 

Adrian Dobson is executive director of professional services

The RIBA Guide to the Building Safety Act is available to RIBA members on 


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