The Biggest Fire Safety Challenges Facing Developers Today

A More Demanding Environment for Developers

Developing residential buildings in the UK has become significantly more complex from a fire safety perspective since the Building Safety Act 2022 came into force. The gateway process, the Building Safety Regulator's role as building control authority for higher-risk buildings, the dual staircase debate, and the ongoing cladding remediation challenge have all added layers of complexity, cost, and programme risk to residential development. Understanding the biggest fire safety challenges facing developers today is the first step to managing them effectively.

Challenge 1: Gateway 2 Programme Risk

For developers of higher-risk buildings, Gateway 2 is now one of the most significant programme risks on any residential project. The Building Safety Regulator has a statutory 8-week assessment period, but applications that are incomplete or that contain inadequate fire safety documentation — including fire strategies that do not meet the BSR's expectations — are returned without assessment and the clock restarts. In the early years of the BSR's operation, some Gateway 2 applications have taken significantly longer than 8 weeks to resolve, causing material delays to construction programmes and significant additional cost.

Managing this risk requires comprehensive fire safety documentation from the outset, early appointment of a competent chartered fire engineer, pre-application engagement with the BSR where the project involves complex or novel fire safety solutions, and a programme that accounts for the possibility of BSR queries and resubmissions.

Challenge 2: The Single Staircase Question

The question of whether new residential buildings over 18 metres should have one or two escape staircases has become one of the most contentious issues in UK residential development. NFCC guidance recommends dual staircase provision for new buildings over 18 metres, and the BSR has applied this expectation to Gateway 2 applications for tall residential buildings. For developers who have designed schemes around a single core, this expectation — if it leads to a Gateway 2 rejection — can require costly redesign with loss of floor area and programme delay.

Challenge 3: External Wall Specification Compliance

Regulation 7(2) restricts the use of combustible materials in the external walls of buildings over 18 metres. Achieving a high-quality architectural finish with fully compliant external wall materials is a genuine design challenge, particularly for buildings that aspire to use timber cladding, certain metal composite materials, or other products that may not meet the combustibility requirements. Fire engineering solutions — including enhanced sprinkler protection and performance-based analysis — can in some cases support the use of materials that would otherwise be non-compliant, but these solutions require robust engineering justification that the BSR will scrutinise carefully.

Challenge 4: Competence Shortages

The increased demand for chartered fire engineers — driven by the gateway process, building safety case requirements, and the growing volume of retrospective fire strategies needed for existing buildings — has created a shortage of suitably qualified and experienced professionals. Developers who do not appoint their fire engineer early in the programme risk finding that the most experienced practitioners are not available at the time they are needed for Gateway 2 preparation.

Challenge 5: Managing Fire Safety Through the Supply Chain

Fire safety on a construction project is only as good as the weakest link in the supply chain. Contractors who install fire stopping incorrectly, suppliers who provide non-compliant fire doors, and subcontractors who modify compartment walls without notification all have the potential to create fire safety deficiencies that are expensive to remediate and that may prevent Gateway 3 from being passed. Robust fire safety management through the construction supply chain — including competence requirements for subcontractors working on fire safety elements — is increasingly a BSR expectation.