RIBA responses to government consultations on fire safety

Since the devastating fire at Grenfell Tower in Kensington, London in 2017, the Royal Institute of British Architects (RIBA)’s Expert Advisory Group on Fire Safety has been responding to government consultations and working with the Department for Levelling Up, Housing and Communities and other key stakeholders to promote the importance of fire safety in good design.

Read more about the RIBA’s fire safety work.

Architects Registration Board: Consultation on draft guidance for a Continuing Professional Development (CPD) scheme

December 2022

This consultation asked for views on the draft guidance as part of ARB's new CPD scheme, before it is finalised and comes into force.

We outlined how our long established CPD system serves to maintain and improve high quality and effective competency standards – and welcomed that ARB’s proposals seek to bolster, rather than duplicate this. Reforms to competency requirements must reflect and cater to the practical needs of the profession whilst instilling confidence in the sector and public too.

Read our full response to the consultation on draft guidance for a Continuing Professional Development (CPD) scheme. (PDF)

Department for Levelling Up, Housing and Communities: Consultation on implementing the new building control regime for higher-risk buildings and wider changes to the build regulations for all buildings

October 2022

This consultation sought views on proposed legislation to create building control procedure for higher-risk buildings.

Our response aims to bolster the policy aims of the Government and ensure the recommendations of Dame Judith Hackitt effect real change within the construction industry, both at a regulatory and behavioural level. Our comments fall under two areas: deliverability of the regulatory process and assurance of built quality.

Read our full response to the consultation on the new building control regime for higher-risk buildings. (PDF)

Department for Levelling Up, Housing and Communities: Consultation on the Higher Risk Buildings (Descriptions and Supplementary Provisions) Regulations

July 2022

This consultation sought views on which buildings are included and excluded in relation to the design and construction part of the new regime and the definitions of these buildings and the method for measuring height and number of storeys.

Our response suggests that the definition of a building in the regulations and the Building Act should be aligned and welcomes the proposal to include care homes and hospitals in the higher risk building definition.

Read our full response to the consultation on the Higher Risk Buildings Regulations. (PDF)

Architects Registration Board: Consultation on draft guidance for Professional Indemnity Insurance

July 2022

This consultation called for views on the Architects Registration Boards (ARB) new draft guidance on professional indemnity insurance (PII) arrangements architects.

Our response noted that the changes proposed are sensible and proportionate – and are likely to reflect what is available to architects in the medium term. However, this new guidance is unlikely to improve architects’ access to PII as it is the insurance market that is in control of what cover is available. The RIBA is concerned that should smaller practices be unable to secure insurance on an aggregate basis they will be forced into closure or will move into the unregulated sector.

Read our response to the consultation on draft guidance for PII. (PDF)

Levelling Up, Housing and Communities Committee: Building safety: remediation and funding

February 2022

This inquiry aims to examine the effectiveness and impact of the government’s planned measures to make developers and industry cover the costs of remediation, to scrutinise whether the Secretary of State’s approach goes far enough to finally fix this crisis, and to examine what the funding arrangement to be agreed with industry should look like.

Our response welcomed the announcement of an additional £4 billion fund to address building safety concerns in mid-rise buildings. However, we noted concerns about the quantity of funding that will be available, the scope of the new announcement and the means by which it is proposed to raise this money.

Read our response to the Levelling Up, Housing and Communities Committee inquiry on building safety funding. (PDF)

Ministry for Housing, Communities and Local Government: proposed amendments to the Architects Act 1997

January 2021

This consultation considers amendments to the Architects Act 1997 to promote and maintain standards of competence amongst architects registered in the UK, relating to building safety. Part A of the consultation expands on provisions in the draft Building Safety Bill, which takes forward the government’s commitment to fundamental reform of the building safety system.

Our response was shaped by views of our members and the wider profession and supports the need for a robust new mandatory competency system, but warns against any regime that would become an expensive, administrative burden for architects.

Read our response to the consultation on proposed amendments to the Architects Act 1997. (PDF)

Home Office: fire safety consultation

October 2020

This consultation sought views on proposals to strengthen the Fire Safety Order, implement Grenfell Tower inquiry recommendations and strengthen the regulatory framework for how building control bodies consult with fire and rescue authorities.

Our response focused on areas including expanding the duties for the Responsible Persons, the quality of fire risk assessments, the definition of height for high rise buildings, evacuation plans and more.

Read our response to the Home Office: fire safety consultation. (PDF)

House of Commons Housing, Communities and Local Government Select Committee: pre-legislative scrutiny of the draft Building Safety Bill

September 2020

The draft Building Safety Bill takes forward reforms of the building safety system in line with the proposals confirmed in the response to the Building a Safer Future consultation, published in April 2020.

The Housing, Communities and Local Government Select Committee launched this inquiry to collate evidence from experts from across sectors on the draft Bill, which detailed how the government intends to deliver the principles and recommendations for reform set out by Dame Judith Hackitt’s Independent Review of Building Regulations and Fire Safety. The RIBA welcomes the intentions of the draft Bill to provide long overdue power to amend the Building Regulations and has provided detailed comments on the proposals for regulatory reform.

Read our full response to the MHCLG Draft Building Safety Bill consultation. (PDF)

Ministry of Housing, Communities and Local Government: review of the ban on the use of combustible materials in and on the external walls of buildings

May 2020

The Ministry of Housing, Communities and Local Government sought views on the restriction on combustible materials in and on the external walls of buildings.

Our response recommended that the restriction should be extended to include hotels, hostels and boarding houses, and all buildings where a catastrophic event could cause multiple fatalities.

Read more about our response to the review of the ban on the use of combustible materials.

Ministry of Housing, Communities and Local Government: sprinklers and other fire safety measures in new high-rise blocks of flats

November 2019

This consultation outlined the government’s intention to amend Approved Document B to reduce the trigger height at which sprinkler systems would be required in new high-rise blocks of flats and asks for views on the trigger height options.

We recommended that sprinklers are a highly effective means of life protection and sprinklers should be a regulatory requirement in all new and converted dwellings. We also recommended that there should be the requirement for centrally addressable fire alarm systems in all new and converted buildings that include a ‘flat’ or a ‘room for residential purposes’ of any height.

Read our full response to the consultation on sprinklers in residential buildings.

Ministry of Housing, Communities and Local Government: building a safer future – proposals for reform of the building safety regulatory system

July 2019

The Ministry of Housing, Communities and Local Government sought views on proposals to achieve long-term reform of the building safety system.

Our response recommended that the proposed regulatory system should not stop at multi-occupancy residential buildings of 18 metres and above from ground level, but should include the following other types of building at any height: supported and sheltered housing, care homes, hospitals, schools and residential educational buildings, prisons and detention centres, places of assembly and hotels and hostels.

Read more about our proposals for a reform of the building safety regulatory system. (PDF)

Department for Education: review of Building Bulletin 100 – design for fire safety in schools

May 2019

The Department for Education asked experts to help review the Building Bulletin 100, which is a design guide for fire safety in schools.

Our response highlighted the importance of the inclusion of prescriptive baseline requirements on life safety measures, for example, maximum travel distances, ventilation, protected lobbies and refuges.

Read our response to the Department for Education. (PDF)

Ministry of Housing, Communities and Local Government: technical review of Approved Document B of the Building Regulations

March 2019

This consultation sought views on the future technical guidance contained within Approved Document B (fire safety).

We recommended that the requirement for sprinklers, alternative means of escape and centrally addressable fire alarms should be included in Approved Document B.

Read our response to the technical review of Approved Document B. (PDF)

Ministry of Housing, Communities and Local Government: banning the use of combustible materials in the external walls of high-rise residential buildings

August 2018

The Ministry of Housing, Communities and Local Government consulted on banning the use of combustible materials in cladding systems on high-rise residential buildings.

Our response included that significant products in external wall construction for existing or new buildings over 18 metres in height must be certified ‘non-combustible’.

Read our full response to the consultation on banning the use of combustible materials on the external walls of high-rise residential buildings. (PDF)

Independent Review of Building Regulations and Fire Safety: Hackitt review

October 2017

The Independent Review of Building Regulations and Fire Safety was announced by government following the Grenfell Tower tragedy and was led by Dame Judith Hackitt.

We highlighted that the current building, housing and fire safety legislation, associated guidance and compliance routes are ambiguous and open to widely varying interpretation. We also recommended that clarity about the roles, responsibilities and accountabilities of different individuals and businesses in relation to fire safety at each stage of the design and construction process would be welcomed. 

Read our full response to the Hackitt review. (PDF)

Grenfell Tower Inquiry: terms of reference of the inquiry

July 2017

The Chair of the Grenfell Tower Inquiry, Sir Martin Moore-Bick consulted on the terms of reference for the inquiry.

We proposed that the inquiry must have the broadest possible remit to examine the overall regulatory and procurement context for construction of buildings, to ensure that any systemic issues that may impact on the design, quality of construction and safety of buildings in respect of fire and which could have contributed to the Grenfell Tower fire were brought under appropriate scrutiny.

Read our full response to the Grenfell Tower inquiry.

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