The Building Safety Act and Fire Strategies

The Building Safety Act 2022 has transformed the role of fire strategies in the development process for higher-risk buildings. Where previously a fire strategy was primarily a document produced for building control, it is now a central document in a three-stage gateway approval process that involves the Building Safety Regulator at planning, pre-construction and completion stages.

Gateway 1 — Planning Stage

The first requirement introduced by the Building Safety Act is the Gateway 1 fire statement, which must be submitted with planning applications for higher-risk buildings. The fire statement demonstrates that fire safety has been considered from the outset of the design process and is a condition of planning permission being granted.

The Gateway 1 fire statement is not a full fire strategy — it is a high-level document produced at planning stage when detailed design information is not yet available. However it sets the direction for the fire strategy that will follow and must be produced by a competent fire engineer.

Gateway 2 — Pre-Construction Stage

Gateway 2 is the most significant change introduced by the Building Safety Act for higher-risk building developers. Before construction can begin, the Building Safety Regulator must approve the building's design — including a comprehensive fire strategy report. This is a substantive technical review, not a rubber stamp, and the BSR has the power to require design changes before granting approval.

The Gateway 2 fire strategy must be significantly more detailed than a standard building control fire strategy. It must demonstrate compliance with Approved Document B, BS 9991 and the specific BSR requirements for higher-risk buildings, and must be produced by a chartered fire engineer with appropriate competence.

Gateway 3 — Completion Stage

At completion, the Principal Contractor must submit a final set of documents to the BSR confirming that the building was constructed as designed. Updated fire safety documentation — including any changes to the fire strategy that occurred during construction — forms part of this submission. The BSR must confirm the building is safe before it can be occupied.

The Golden Thread

The Building Safety Act also introduces the concept of the golden thread — a digital record of information about a higher-risk building that must be maintained throughout its life. The fire strategy is a key component of the golden thread and must be kept up to date as the building changes.