Fire Safety Frequently Asked Questions

Whether you need a fire strategy report depends on the nature of your project and the regulatory requirements that apply to it. As a general rule, a fire strategy report is required in the following circumstances:

• New build projects submitted for building control approval — virtually all new buildings of any significance require a fire strategy to accompany the building control submission
• Higher-risk buildings under the Building Safety Act 2022 — any new residential building over 18 metres or 7 storeys requires a fire statement at planning (Gateway 1) and a full fire strategy at pre-construction stage (Gateway 2)
• Major planning applications in Greater London — London Plan Policy D12a requires a fire statement for all major planning applications in Greater London, regardless of height
• Refurbishment projects affecting fire safety — works that alter escape routes, change compartmentation, or affect the fire safety systems of an existing building typically require a fire strategy
• Change of use — converting offices to residential, houses to HMOs, or any change of occupancy requires a fire strategy addressing the new use
• Building Safety Regulator registration — existing higher-risk buildings registering with the BSR require a building safety case, of which a fire strategy (or retrospective fire strategy) is a central component

If you are unsure whether your project requires a fire strategy, Fire Safety Services provides a free initial assessment. Contact us with the building type, address and proposed works and we will advise within 1 to 2 working days.

A fire strategy report must be produced by a competent fire engineer. For all but the simplest projects, this means a Chartered Engineer (CEng) with professional membership of the Institution of Fire Engineers (IFE) or the Institution of Mechanical Engineers (IMechE) — or a fire engineer working under the direct supervision of such a person.

The Building Safety Regulator is explicit about this for higher-risk buildings: Gateway 2 fire strategy submissions are expected to be produced by or under the supervision of a chartered fire engineer with relevant project experience. Submissions produced by individuals without appropriate qualifications are increasingly being queried or rejected.

It is important to distinguish between fire engineers and fire risk assessors. Fire risk assessors are qualified to assess occupied buildings under the Regulatory Reform (Fire Safety) Order 2005, but they are not typically qualified to produce fire strategy reports for design-stage purposes. Similarly, not all "fire safety consultants" are chartered fire engineers.

When appointing a fire strategy consultant, always ask:

• Does the lead engineer hold CEng status?
• Are they a member of the IFE or IMechE?
• Do they have experience of projects of similar type and scale?
• Can they provide references or examples of similar work?

Fire Safety Services is an independent chartered fire engineering practice. All fire strategy reports are produced by or under the direct supervision of Chartered Engineers with IFE membership.

Fire strategy report fees vary depending on the size and complexity of the project, the applicable standards, whether performance-based fire engineering is required, and the level of detail needed for the building control or Building Safety Regulator submission.

As a general guide:

• Simple residential conversions or small commercial fit-outs: From £1,500 to £3,500 + VAT
• Mid-scale residential or commercial new builds (under 18m): Typically £3,500 to £8,000 + VAT
• Higher-risk buildings (Gateway 2 fire strategies): Typically £8,000 to £25,000+ + VAT depending on complexity
• Complex or performance-based fire engineering projects: Fees are project-specific and agreed in advance

Fire Safety Services provides fixed-fee proposals for all projects. We respond to all fee enquiries within 1 to 2 working days with a clear scope of services, fee, and confirmation of timescales. There are no hidden charges — our fee is the fee.

We would also note that the fee for fire strategy consultancy is typically one of the smallest professional fees on any significant development project — and one of the highest in terms of risk management value. A fire strategy issue identified at RIBA Stage 4 or at building control can cost many times the fire engineering fee to resolve.

To produce a fire strategy report, a fire engineer typically requires the following information:

• Architectural drawings: Floor plans, sections and elevations at a sufficient stage of development to allow travel distances to be measured, compartmentation to be identified, and escape routes to be assessed. At building control stage, these should be the technical design drawings
• Structural drawings: Structural framing plans and sections, enabling the fire engineer to specify structural fire protection requirements
• Building description: Use, occupancy, number of floors, gross floor areas, and any specific operational characteristics relevant to fire safety
• M&E information: Where smoke control, suppression systems or fire detection systems are proposed, the fire engineer needs information about the systems being designed
• Planning history: For higher-risk buildings, the planning fire statement (Gateway 1) is required so the building control fire strategy can be consistent with it
• Previous fire engineering input: Any previous fire strategy, fire engineering report, or building control correspondence relevant to the project

For retrospective fire strategies (existing buildings), site inspection is also required, along with any available as-built drawings, O&M manuals and maintenance records.

Fire Safety Services will confirm exactly what information is required at the time of instruction, and can start work from concept drawings where a project is at an early stage.

The time required to produce a fire strategy report depends on the complexity of the project and the completeness of the information provided.

• Straightforward projects (simple residential conversions, small commercial projects): 5 to 10 working days from receipt of complete information
• Mid-scale projects (residential new builds under 18m, commercial fit-outs, change of use): 7 to 14 working days
• Complex or higher-risk building projects (Gateway 2 fire strategies, performance-based fire engineering): 3 to 6 weeks depending on complexity
• Retrospective fire strategies for existing buildings: 3 to 6 weeks including site inspection and information gathering

Fire Safety Services confirms delivery timescales at the time of issuing a fee proposal. Where programme constraints require a faster turnaround, please mention this in your initial enquiry and we will advise whether an accelerated programme is achievable.

Note that programme time is from receipt of all required information. Incomplete information at the point of instruction is the most common cause of delays.

Yes. A fire strategy report for an existing building is called a retrospective fire strategy. It is an increasingly common instruction, driven primarily by the Building Safety Act 2022's requirement for higher-risk buildings to register with the Building Safety Regulator and produce a building safety case.

A retrospective fire strategy differs from a new build fire strategy in that the fire engineer must work with the building as it exists, rather than designing from scratch. The process involves:

• Gathering existing information — as-built drawings, previous fire safety surveys, O&M manuals
• Site inspection to verify building configuration, materials and fire safety systems
• Assessment of the building against current fire safety standards
• Identification of any gaps between existing provision and current requirements
• A schedule of recommended remedial works, prioritised by risk

Importantly, existing buildings are not required to comply with current building regulations as if they were newly built — they must demonstrate that they are safe, taking into account what is reasonably practicable. A retrospective fire strategy takes this proportionate approach.

Common triggers for retrospective fire strategies include BSR registration, insurance requirements, lender requirements, refurbishment works, and change of use.

No. Building control bodies — whether local authority building control (LABC) or registered building control approvers (RBCAs) — assess the technical quality of fire strategy reports and have the authority to query, reject, or require revision of submissions they consider inadequate.

The most common reasons building control bodies reject or query fire strategy reports include:

• The report describes a different building from the drawings submitted (poor coordination)
• Travel distances exceed Approved Document B limits without adequate justification
• Compartmentation is specified in the report but not shown on the drawings
• The fire door schedule is missing or incomplete
• Structural fire protection specifications are absent or inconsistent with the structural design
• Firefighting facilities are inadequate for the building height
• The disabled evacuation strategy is not addressed

For higher-risk buildings, the Building Safety Regulator applies additional scrutiny at Gateway 2. BSR reviewers include chartered fire engineers who will assess the quality and completeness of fire strategy submissions in detail.

The quality of the fire strategy — and the competence of the engineer who produces it — directly affects the building control and Gateway 2 outcome. This is why Fire Safety Services checks all fire strategies against the current drawing set before issue.

The consequences of a missing fire strategy depend on whether the building is in design, under construction, or occupied.

For buildings in design or construction: A building control application without a fire strategy will be queried or rejected. The programme delay while a fire strategy is produced and agreed with the building control body is typically 4 to 12 weeks. Where the fire strategy identifies design issues requiring changes, this can extend significantly.

For higher-risk buildings at Gateway 2: Construction cannot begin without BSR approval, and a comprehensive fire strategy is required for Gateway 2. Missing or inadequate fire strategy documentation is one of the primary causes of Gateway 2 delays.

For occupied existing buildings: The absence of a fire strategy is not in itself an immediate legal offence under most circumstances, but it creates regulatory and liability exposure:

• Higher-risk buildings without a building safety case (which must include a fire strategy) are in breach of the Building Safety Act 2022
• Insurers are increasingly requiring fire strategies for buildings above certain height or complexity thresholds
• Fire service enforcement action under the RRO 2005 may result in requirements that could have been avoided with a proper fire strategy
• Where a fire causes injury or death, the absence of a fire strategy may be a significant factor in any resulting civil or criminal liability

If your building does not have a fire strategy, commissioning a retrospective fire strategy is a straightforward first step. Fire Safety Services can advise on the scope and cost within 1 to 2 working days of an initial enquiry.

A fire engineer should be appointed at the earliest opportunity on any project involving the design, refurbishment or assessment of a building. In practice, the most common triggers for appointing a fire engineer are:

• New build projects: Ideally at RIBA Stage 1 or 2, when the fundamental design decisions that affect fire safety are being made
• Planning applications: For higher-risk buildings (Gateway 1) and all major applications in Greater London (D12a), a fire engineer is needed to produce the planning fire statement
• Building control submissions: A fire strategy report is required for most building control applications
• Higher-risk building Gateway 2 submissions: A comprehensive fire strategy must be submitted to and approved by the Building Safety Regulator before construction can begin
• Refurbishment and change of use: Where works affect escape routes, compartmentation or fire safety systems
• BSR registration for existing buildings: A building safety case is required, with a fire and structural safety assessment at its core
• FRAEW and PAS 9980 assessments: External wall fire risk assessments require a fire engineer with specific PAS 9980 competency

The earlier a fire engineer is appointed, the greater the value they add. A fire engineering review at RIBA Stage 2 typically costs a fraction of the cost of resolving fire safety issues at Stage 4 or during building control.

This is one of the most commonly misunderstood distinctions in fire safety. Fire engineers and fire risk assessors are distinct professions with different roles, qualifications and responsibilities.

Fire engineer

• Works at design stage — on new buildings, refurbishments, and change of use
• Produces fire strategies, building control fire engineering reports, planning fire statements, Gateway 2 submissions, FRAEW assessments and building safety cases
• Applies engineering principles and analysis to fire safety design
• Typical qualification: Chartered Engineer (CEng) with IFE or IMechE membership
• Regulated by the Building Safety Regulator for higher-risk building work

Fire risk assessor

• Works on occupied buildings — assessing fire hazards and risks under the Regulatory Reform (Fire Safety) Order 2005
• Produces fire risk assessments, recommends control measures, and supports the responsible person in managing fire safety
• No formal engineering analysis required — focuses on hazard identification and risk management
• Typical qualification: NEBOSH Fire Safety, IFE membership, or professional registration with a fire risk assessor body
• Does not need to be a chartered engineer

Both disciplines are important, but at different stages of a building's life. Where confusion arises — sometimes with significant consequences — is when a fire risk assessor is asked to produce a fire strategy, or when a fire engineer is asked to carry out a fire risk assessment without appropriate training. Always confirm the qualifications of your consultant match the work required.

Yes — and this is one of the most compelling arguments for appointing a fire engineer early in the design process. The single most common cause of expensive late-stage building alterations is fire safety issues that were not identified and addressed during the design phase.

Examples of costly alterations that early fire engineering prevents:

• Escape stair repositioning: An escape stair in the wrong location — creating travel distance exceedances — discovered at building control stage can require significant structural and architectural redesign. Identified at RIBA Stage 2, it is a straightforward layout change
• Compartmentation additions: A missing compartment wall that requires structural modifications to add. Designed in from the start, it is a line on a drawing. Retrofitted during construction, it can cost tens of thousands
• Facade redesign: A combustible facade system that fails the ADB external fire spread requirements for buildings over 18 metres. Identified at Stage 2, it can be designed out. Identified at Stage 4 or Gateway 2, it requires a complete facade redesign
• Sprinkler system addition: Discovering that sprinklers are required at building control stage — when ceiling void depths and plant room space have already been fixed — is significantly more expensive than designing for sprinklers from the start

A RIBA Stage 2 fire engineering review typically costs a few thousand pounds. The cost of a single late-stage redesign driven by a fire safety issue typically runs to tens or hundreds of thousands. The return on investment from early fire engineering appointment is consistently one of the highest of any professional fee on a development project.

Fire engineering consultancy fees vary depending on the type of service, the complexity of the project, and the level of engineering analysis required. The following provides a general guide:

• RIBA Stage 2 fire engineering review: £1,500 to £4,000 + VAT — typically a half to full day review with a brief written report
• Planning fire statement (Gateway 1 or D12a): £2,000 to £6,000 + VAT depending on building size and complexity
• Building control fire strategy: £2,500 to £15,000 + VAT — depending on building type, scale and regulatory route
• Gateway 2 fire strategy for higher-risk buildings: £8,000 to £30,000+ + VAT — reflecting the greater depth and complexity required
• FRAEW assessment (PAS 9980): From £3,000 to £10,000+ + VAT depending on building size and investigation required
• Building safety case production: Highly variable — from £10,000 for a well-documented smaller building to £50,000+ for a large complex scheme with significant documentation gaps
• Performance-based fire engineering and CFD modelling: Project-specific, typically £8,000 to £25,000+ depending on the number of scenarios

Fire Safety Services provides fixed-fee proposals for all work. We respond to all fee enquiries within 1 to 2 working days.

A PAS 9980 assessment is required in the following main circumstances:

• Mortgage lending: Where a lender requires an EWS1 form before lending against flats in a residential building, the EWS1 must be based on a proper PAS 9980 Fire Risk Appraisal of External Walls (FRAEW). RICS guidance limits the circumstances in which lenders should require EWS1, primarily to buildings with cladding, render or combustible materials in the external wall
• Building Safety Regulator registration: Higher-risk buildings (over 18 metres or 7 storeys with residential units) must register with the BSR and produce a building safety case. An external wall assessment under PAS 9980 is a key component of this
• Freeholder/managing agent due diligence: Following the Fire Safety Act 2021, the scope of fire risk assessments for multi-occupied residential buildings was extended to include external walls. PAS 9980 provides the appropriate methodology for this assessment
• Insurance requirements: Some insurers now require external wall fire safety assessments for residential buildings above certain heights

Not all residential buildings require a PAS 9980 assessment. Buildings with entirely non-combustible external walls (brick, stone, or concrete without combustible insulation) are generally low risk and may not require a full assessment. If you are unsure, Fire Safety Services can carry out a brief desktop review to advise.

PAS 9980 and EWS1 are frequently confused because they are related — but they are different things:

PAS 9980:2022 is a British Standard published by the BSI that provides the methodology for carrying out a Fire Risk Appraisal of External Walls (FRAEW). It defines who is qualified to carry out the assessment, what information must be gathered, how the site inspection should be conducted, and how findings should be reported and communicated. PAS 9980 is the process.

EWS1 (External Wall System Fire Review) is a form — originally developed by UK Finance, the Building Societies Association and RICS — that records the outcome of an external wall assessment for the purpose of mortgage lending. The EWS1 form is completed following a PAS 9980 FRAEW assessment and assigns one of five ratings (A1, A2, A3, B1 or B2) that mortgage lenders use to determine whether and on what terms they will lend against flats in the building. EWS1 is the output.

In summary: the PAS 9980 FRAEW is the technical work; the EWS1 form is the document that communicates the conclusion of that work to lenders. You cannot produce a valid EWS1 form without carrying out a proper PAS 9980 FRAEW assessment.

EWS1 ratings:

• A1: No combustible materials in the external wall — no further action required
• A2: Combustible materials present — risk assessed as sufficiently low
• A3: Combustible materials present — remediation required
• B1: Cladding/external wall assessed — risk acceptable
• B2: Cladding/external wall requires remediation

PAS 9980:2022 sets out specific competency requirements for those carrying out FRAEW assessments. The assessor must have:

• Knowledge of fire engineering principles as they relate to buildings
• Understanding of external wall construction types, including cladding systems, insulation types, cavity barriers and fire stopping
• Familiarity with the materials commonly used in residential building facades and their fire performance
• Knowledge of the PAS 9980 assessment methodology
• The ability to interpret fire test evidence and apply it to specific buildings

RICS guidance states that EWS1 forms should be completed by suitably competent professionals — typically chartered fire engineers or, in certain circumstances, chartered structural engineers with specific external wall fire safety competency.

In practice, the most appropriate assessors are chartered fire engineers (CEng, IFE or IMechE) with specific PAS 9980 training and experience. The competency requirements were strengthened following early concerns that EWS1 forms were being completed by individuals without adequate qualifications.

Fire Safety Services's PAS 9980 assessors are chartered engineers with specific PAS 9980 competency, meeting RICS requirements for EWS1 sign-off.

The duration of a PAS 9980 assessment depends on the size and complexity of the building and whether intrusive investigation of the external wall is required.

• Simple assessment (good information available, straightforward building): 2 to 4 weeks from instruction to issuing the FRAEW report and EWS1 form
• Standard assessment (some investigation required): 3 to 6 weeks
• Complex assessment (limited information available, intrusive investigation required): 6 to 10 weeks or more, as the intrusive investigation must be planned, executed and the findings incorporated

The assessment process includes:

1. Desktop review of all available building information (drawings, specifications, material certificates)
2. Site inspection — typically half a day to a full day per block
3. Intrusive investigation where required — arranged separately, subject to access
4. FRAEW report preparation and quality review
5. Issuing the FRAEW report and EWS1 form

Fire Safety Services confirms timescales at the point of instruction and keeps clients updated on progress. Where leaseholders are waiting to sell or remortgage, we understand the urgency and aim to work as quickly as the assessment process permits.

Your building needs an EWS1 form if a mortgage lender requires one before lending against flats in the building. Whether a lender requires an EWS1 form depends on the lender's policy and the characteristics of the building.

RICS guidance (updated in 2021) limits the circumstances in which lenders should require EWS1 forms. According to this guidance:

• Buildings with cladding of any type, on any storey: EWS1 typically required
• Buildings with balconies using combustible decking, cladding or structures: EWS1 typically required
• Buildings under 18 metres with no cladding and no balcony concerns: EWS1 typically not required by lenders
• Buildings over 18 metres: Assessment depends on external wall characteristics

In practice, many lenders have their own internal policies that may differ from RICS guidance. The most reliable way to determine whether your building needs an EWS1 form is to check with the lender who has declined to lend or required the form.

Note that even where mortgage lenders do not require an EWS1 form, the Building Safety Regulator may require an external wall assessment for higher-risk buildings as part of the building registration process.

The cost of an EWS1 assessment — which includes a PAS 9980 Fire Risk Appraisal of External Walls (FRAEW) — depends on the size of the building, the complexity of the external wall system, the quality of available information, and whether intrusive investigation is required.

As a general guide:

• Small residential block (under 6 storeys, well-documented): From £3,000 to £5,000 + VAT
• Mid-scale residential block (6 to 12 storeys): £5,000 to £8,000 + VAT
• Large or complex blocks, or those requiring intrusive investigation: £8,000 to £15,000+ + VAT
• Large portfolios of blocks: Portfolio pricing is available — contact us for details

These fees cover the FRAEW assessment and the EWS1 form. Where intrusive investigation of the external wall is required — opening up the wall to inspect materials that cannot be identified from available information — the investigation itself is typically funded separately by the building owner and arranged by the assessor.

Fire Safety Services provides fixed-fee proposals following an initial desktop review, giving you clarity on cost before instructing the full assessment.

In some cases yes, but it depends on your buyer's lender. If the buyer is purchasing with a mortgage and their lender requires an EWS1 form for your building, the sale cannot proceed until the form is provided — unless the buyer is a cash buyer who can purchase without a lender requirement.

The situation is complex and has affected thousands of leaseholders across the UK. The key points are:

• EWS1 forms are required by lenders, not by law. A cash buyer does not need an EWS1 form
• Where a lender requires an EWS1 form, it must be provided by the freeholder or managing agent — not the individual leaseholder. If your building does not have an EWS1 form, you need to request one from your freeholder
• RICS guidance has been revised to limit the buildings for which EWS1 forms are required. Some buyers' lenders may not require an EWS1 form for your building even if a previous lender did
• Where the building requires cladding remediation before a satisfactory EWS1 can be issued, government funding programmes — including the Building Safety Fund and the developer remediation contract — may provide a route to remediation

If you are a leaseholder unable to sell because of an EWS1 issue, the first step is to contact your freeholder or managing agent and formally request that they commission a PAS 9980 assessment. Fire Safety Services can advise on the process and timescales.

EWS1 forms do not have a fixed expiry date. However, they should be reviewed — and may need to be reissued — in the following circumstances:

• Changes to the external wall: Any works that affect the external wall — re-cladding, additional insulation, replacement of balcony materials — may require the EWS1 to be reissued based on the revised wall
• New information about materials: If new information comes to light about the fire performance of materials in the external wall — for example following test failures of materials previously considered acceptable — the EWS1 may need to be reviewed
• Material change in the regulatory framework: If guidance or standards change in a way that affects the assessment of the external wall
• Time elapsed: While there is no fixed expiry, most practitioners treat EWS1 forms as needing review after approximately 5 years

In practice, EWS1 forms issued following proper PAS 9980 assessments with A1 or B1 ratings are generally accepted by lenders for as long as the above circumstances have not changed. Where a lender declines to accept an existing EWS1 form, the assessor who issued it should be contacted to confirm whether a review or reissue is required.

Building owners — whether developers, freeholders or institutional investors — should hold the following core fire safety documents for their buildings:

For all occupied non-domestic and multi-residential buildings:

• Fire risk assessment: Required under the Regulatory Reform (Fire Safety) Order 2005. Must be suitable and sufficient, reviewed at least annually, and updated following any significant change
• Fire evacuation plan: The documented procedure for evacuation in the event of a fire, communicated to all occupants
• Fire safety maintenance records: Records of testing and maintenance of fire detection and alarm systems, emergency lighting, fire doors, suppression systems and smoke control systems

For buildings that have been designed or significantly refurbished:

• Fire strategy report: The engineering document produced at design stage setting out the building's fire safety design
• As-built drawings with compartmentation: Plans showing fire compartment boundaries, fire resistance periods, fire door locations and fire stopping
• Fire door schedule: Listing all fire doors, their performance ratings and maintenance requirements

For higher-risk buildings (over 18 metres or 7 storeys with residential units):

• Building safety case report: Required under the Building Safety Act 2022
• Golden thread documentation: The complete set of building information required to be maintained throughout the building's life
• BSR registration confirmation

For buildings with cladding or external wall concerns:

• PAS 9980 FRAEW report and EWS1 form

A building safety case report is the central compliance document required by the Building Safety Act 2022 for higher-risk buildings — those over 18 metres or 7 storeys containing at least two residential units in England.

The building safety case report is produced by or for the accountable person of the building and must be submitted to the Building Safety Regulator when required. It summarises the evidence that demonstrates the building is safe for occupation.

A building safety case report typically contains:

• A description of the building — layout, construction, occupancy, key safety systems
• The fire safety assessment — typically based on a fire strategy or retrospective fire strategy, supported by a current fire risk assessment
• The structural safety assessment
• A summary of the key building information held — as-built drawings, specifications, material certificates
• Evidence of the fire safety management arrangements in place
• Records of resident engagement
• Confirmation of compliance with ongoing testing and maintenance obligations

The building safety case is a living document — it must be kept up to date as the building changes and as management arrangements evolve. Fire Safety Services uses a structured five-stage methodology for building safety case production, from initial gap analysis through to BSR submission.

The principal accountable person (PAP) is the individual or organisation that holds a legal estate in the whole of the common parts of a higher-risk building. In most cases, this is the freeholder.

The PAP role was introduced by the Building Safety Act 2022 and carries the highest level of statutory duty for the safety of higher-risk buildings. Where there is more than one accountable person for a building — for example where different parts of the building are owned by different parties — one must be designated as the principal accountable person.

The PAP's key duties include:

• Registering the building with the Building Safety Regulator
• Producing and maintaining a building safety case
• Submitting a building safety case report to the BSR when required
• Appointing a building safety manager
• Maintaining the golden thread of building information
• Implementing the mandatory resident engagement strategy
• Reporting prescribed events to the BSR

The PAP cannot delegate their legal responsibility. They can appoint others — including managing agents and building safety managers — to assist in carrying out these obligations in practice, but remain personally liable for compliance.

Failure to comply with PAP duties is a criminal offence under the Building Safety Act, carrying unlimited fines and potentially imprisonment.

Under the Building Safety Act 2022, a higher-risk building in England is defined as a building that:

• Is at least 18 metres tall (measured from ground level to the top floor), or has at least 7 storeys
• Contains at least two residential units

This definition covers a wide range of building types, including:

• Tall blocks of flats — whether new build or existing
• Mixed-use buildings with residential above the 18-metre threshold
• Purpose-built student accommodation meeting the height threshold
• Build-to-rent developments
• Former commercial buildings converted to residential above 18 metres

Buildings that are NOT higher-risk buildings under the current definition include:

• Buildings below 18 metres and under 7 storeys
• Buildings with only one residential unit (houses, bungalows)
• Hotels, hospitals, care homes and similar non-residential buildings, even where over 18 metres (these may be subject to other regulatory requirements)

The Building Safety Act gives the Secretary of State powers to extend the higher-risk building definition in the future. Building owners should monitor any changes to the definition.

A fire safety statement (also called a planning fire statement or Gateway 1 fire statement) is a document submitted with a planning application to demonstrate that fire safety has been considered from the outset of a building's design.

There are two main forms:

Gateway 1 fire statement — required under the Building Safety Act 2022 for planning applications for higher-risk buildings. Must be completed on the prescribed government form and addresses means of escape, firefighting facilities, evacuation strategy, fire spread, and future management.

London Plan Policy D12a fire statement — required for all major planning applications in Greater London (10 or more dwellings or over 1,000m² of floorspace). Must address all ten fire safety requirements of Policy D12a, including means of escape, external envelope protection, firefighting access, water supply and building management.

A fire safety statement is distinct from a fire strategy report — the fire statement is a planning document produced at an early design stage, while the fire strategy is a detailed building control document produced at technical design stage. The fire statement sets the direction; the fire strategy provides the engineering detail.

Fire safety statements should be produced by a competent fire engineer. Fire Safety Services has an established track record of producing Gateway 1 and D12a fire statements accepted by all London planning authorities and the GLA.

Yes. Building control bodies — whether local authority building control (LABC) teams or registered building control approvers (RBCAs) — have the authority to query, request revision of, or reject fire strategy reports that do not demonstrate compliance with the Building Regulations.

Building control is not a rubber-stamp process. Surveyors review fire strategies technically and will raise queries where they identify issues with travel distances, compartmentation, firefighting facilities, structural fire protection, or coordination with drawings.

The most common reasons fire strategies are rejected or queried:

• Inconsistency between the report and the drawings — the fire strategy describes a layout different from what is shown
• Travel distances that exceed ADB limits without adequate justification
• Missing compartmentation details on drawings
• Incomplete fire door schedule
• Inadequate firefighting facilities for the building height
• Disabled evacuation strategy not addressed

For higher-risk buildings, the Building Safety Regulator applies additional scrutiny at Gateway 2, with a multi-disciplinary review team including chartered fire engineers. BSR rejection at Gateway 2 is more consequential than a building control query — it prevents construction from starting and requires the design to be revised and resubmitted.

The risk of rejection is significantly reduced by appointing a chartered fire engineer who coordinates the fire strategy directly with the current drawing set before submission.

Gateway 2 is the pre-construction approval stage for higher-risk buildings under the Building Safety Act 2022. The Building Safety Regulator must approve the building's design before a building control certificate is issued and construction can begin.

A Gateway 2 submission is a comprehensive package of design information submitted through the building control body to the BSR. The fire safety components of a Gateway 2 submission typically include:

• A detailed fire strategy report — more comprehensive than a standard building control fire strategy, addressing all BSR requirements
• Fire compartmentation drawings — annotated plans and sections showing all compartment boundaries and fire resistance periods
• Fire door schedule — comprehensive listing of all fire doors with performance specifications
• Structural fire protection specification — coordinated with the structural engineer's design
• External wall fire safety evidence — confirming compliance with the non-combustible wall requirement for buildings over 18 metres
• Smoke control design information — performance requirements and system design
• Sprinkler system design basis

The BSR has an initial 8-week period for Gateway 2 decisions, but can extend this for complex submissions or where queries need to be resolved. Incomplete or inadequate submissions are a primary cause of Gateway 2 delays.

Fire Safety Services has specific experience of Gateway 2 submissions and produces fire strategy packages specifically structured for the BSR's requirements.

A fire strategy and a fire safety statement serve different purposes, are produced at different stages of the design process, and contain different levels of detail.

Fire safety statement

• Produced at planning stage (RIBA Stage 2 / 3)
• A high-level document — design information is not fully developed at this stage
• Required for higher-risk buildings (Gateway 1) and major applications in Greater London (D12a)
• Reviewed by the local planning authority (and the BSR / GLA for certain buildings)
• Sets out the overall fire safety approach and confirms fire safety has been considered from the outset

Fire strategy report

• Produced at technical design stage (RIBA Stage 4)
• A detailed engineering document — coordinated with technical design drawings
• Required for building control approval (and Gateway 2 for higher-risk buildings)
• Reviewed by the building control body (and the BSR for higher-risk buildings)
• Contains specific engineering analysis of travel distances, compartmentation, structural fire protection, firefighting facilities, and suppression and smoke control systems

The fire safety statement sets the direction; the fire strategy provides the detail. Both are required for higher-risk buildings — the fire statement at planning stage and the fire strategy at building control / Gateway 2 stage. The fire strategy should be consistent with the commitments made in the fire safety statement.

The term "fire engineering assessment" covers a range of activities depending on the context. Here are the most common types and what they involve:

Design-stage fire engineering review

A review of architectural and structural drawings against fire safety requirements, typically producing a brief report identifying compliance issues and recommendations. Usually carried out at RIBA Stage 2 or 3 as part of the fire strategy development process.

Building control fire strategy production

A detailed fire engineering exercise producing the fire strategy report for building control submission. Involves measurement of travel distances on drawings, specification of compartmentation, structural fire protection and systems, and coordination with other consultants.

PAS 9980 FRAEW assessment

For existing residential buildings with cladding. Involves desktop review of existing information, a site inspection of the external wall, and — where necessary — intrusive investigation. Produces a FRAEW report and, where required, an EWS1 form.

Retrospective fire strategy for an existing building

Involves site inspection, gathering of as-built information, assessment of the building against current standards, and production of a report identifying gaps and recommended remedial works.

Performance-based fire engineering analysis

A more complex exercise involving fire scenario development, computational analysis or modelling, and a detailed engineering report demonstrating that an alternative approach achieves the required level of safety.

A fire strategy should be reviewed whenever circumstances change that may affect its accuracy or validity. There is no single prescribed review interval, but the following guidance applies:

During design and construction: The fire strategy should be updated whenever significant design changes are made — particularly changes that affect escape routes, travel distances, compartmentation, the structural system, or the facade specification. It is good practice to check the fire strategy against the current drawing set at each RIBA stage gate.

For occupied buildings:

• When refurbishment works are carried out that affect means of escape, compartmentation or fire safety systems
• When the use of the building changes — new tenants with different occupancy characteristics, conversion of commercial to residential, etc.
• When the evacuation strategy changes — for example a change from stay-put to simultaneous evacuation in a residential building
• When the fire risk assessment identifies issues that relate to the building's design rather than management
• As part of the building safety case review for higher-risk buildings
• Every five years as a routine review — even where no specific changes have occurred

For higher-risk buildings registered with the Building Safety Regulator, the building safety case — of which the fire strategy is a central component — must be kept up to date. This effectively requires the fire strategy to be reviewed whenever relevant changes occur and as part of the periodic building safety case review.