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.
Levelling Up, Housing and Communities Committee: Building safety: remediation and funding
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.
Ministry for Housing, Communities and Local Government: proposed amendments to the Architects Act 1997
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.
Home Office: fire safety consultation
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.
House of Commons Housing, Communities and Local Government Select Committee: pre-legislative scrutiny of the draft Building Safety Bill
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.
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
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.
Ministry of Housing, Communities and Local Government: sprinklers and other fire safety measures in new high-rise blocks of flats
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.
Ministry of Housing, Communities and Local Government: building a safer future – proposals for reform of the building safety regulatory system
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.
Department for Education: review of Building Bulletin 100 – design for fire safety in schools
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.
Ministry of Housing, Communities and Local Government: technical review of Approved Document B of the Building Regulations
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.
Ministry of Housing, Communities and Local Government: banning the use of combustible materials in the external walls of high-rise residential buildings
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’.
Independent Review of Building Regulations and Fire Safety: Hackitt review
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.
Grenfell Tower Inquiry: terms of reference of the inquiry
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.