RIBA fire safety policy note – February 2022

Our position and asks on the Building Safety Bill, current Building Regulations and the problems around remediation work.

This document outlines the RIBA’s positions and asks regarding the Building Safety Bill, changes to Building Regulations, and the problems around remediation work.

Building Safety Bill

We’ve been clear that the new, proposed building safety system requires tweaks to provide greater clarity on who is responsible for key decisions.

We therefore recommend the new system:

  • requires the appointment of the Principal Designer at Gateway 1 (planning) on higher risk buildings, because key fire safety strategy decisions are made at this stage
  • modifies the wording of the statutory duties to avoid creating uninsurable duties on designers, contractors, Principal Designers, and Principal Contractors
  • provides clearer guidance on requirements for “monitoring” construction compliance.
  • provides a clear, publicly-available specification for Principal Designer competence. This should cover the skills, experience and certifications required.

Find out more about the Building Safety Bill here.

Building Regulations

The Building Regulations, Approved Document guidance, and associated British Standards also need updating to reflect the views of the construction and insurance industries on best practice in higher risk buildings.

This includes:

  • requiring, rather than recommending, sprinklers/automatic fire suppression systems in new and converted residential buildings above 11m, and as ‘consequential improvements’ where a residential building above 18m is subject to 'material alterations'
  • introducing a requirement for centrally addressable fire alarm systems in new and converted residential buildings above 11m, and in all existing residential buildings above 18m from ground level as ‘consequential improvements’ where a building is subject to 'material alterations'
  • commissioning a further study of the fire safety of residential buildings with a single means of escape. The Building Safety Regulator should urgently investigate whether a single means of escape provides for adequate access for firefighters and evacuation of residents in residential buildings and at what height an additional means of escape should be required
  • introducing restrictions on combustible materials on residential buildings over 11m
  • investing in independent, large-scale fire safety testing of new materials and construction methods to investigate real world application and use of materials rather than laboratory conditions (government)
  • undertaking a full review of Approved Document B which should include the above provisions on sprinklers/automatic fire suppression systems, central alarms, means of escape and travel distances, restrictions on the use of combustible materials, and toxicity in fire
  • updating Building Regulations and guidance to deliver more prescriptive routes to compliance for higher risk buildings

Fire safety remediation

The government needs to acknowledge regulatory failure and take action to address the impacts on those affected. Proposals to extend the Defective Premises Act are misguided – and will have negative impacts on the insurability and risk appetite of the construction sector even where no faults are found.

We therefore recommend the establishment of a comprehensive building safety fund to address fire safety failings in the construction of buildings that create unacceptable fire risks, not just through the use of combustible materials.

You can download the full paper below.

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