The most frequently raised fire safety issues by building control bodies — and how to address them before submission.
16 July 20244 min readFire Safety Services
What Building Control Looks for in Fire Safety Submissions
Building control bodies — whether local authority building control, registered building control approvers, or the Building Safety Regulator for higher-risk buildings — assess fire safety submissions against the functional requirements of Part B of the Building Regulations. Certain fire safety issues are raised repeatedly across project types and building control bodies. Understanding these common issues helps developers, architects, and fire engineers produce submissions that address them proactively and avoid the delays that repeated queries cause.
The Most Frequently Raised Fire Safety Issues
Travel distance non-compliance — escape corridor layouts that exceed the maximum travel distances permitted under Approved Document B, BS 9991, or BS 9999. The most common specific failure is a single-direction travel distance that exceeds the permitted limit. Building control will not approve a design where travel distances are non-compliant without engineering justification or design changes.
Inadequate staircase provision — buildings where the number, width, or configuration of escape staircases does not meet the applicable requirements. For taller buildings, the question of whether one or two staircases are required is frequently the subject of detailed discussion with building control.
Fire door specification gaps — fire strategies or specifications that do not fully address fire door requirements, including self-closing devices, intumescent strip and smoke seal specifications, vision panel requirements, and hardware specifications. For higher-risk buildings, fire door schedules must be comprehensive and accurate.
External wall compliance — regulation 7(2) — for buildings over 18 metres, the external wall specification must demonstrate compliance with the restriction on combustible materials in external walls. This is increasingly a priority issue for the BSR at Gateway 2, and submissions that do not clearly address it will be queried.
Sprinkler design basis — where sprinklers are required or are being used to justify relaxations in other fire safety provisions, the design basis must be specified clearly. For residential buildings, BS 9251 or LPS 1301 applies; for commercial buildings, LPC rules or BS EN 12845 may be more appropriate.
Smoke control system performance — for buildings where natural or mechanical smoke control is required, the design must demonstrate that the system will maintain adequate smoke-free height over escape routes. For complex systems, CFD modelling may be required to demonstrate performance.
Firefighting facilities — for buildings over 18 metres, the provision of firefighting shafts, rising mains, and firefighting lifts must meet the requirements of the applicable code. The position of rising mains and the coverage of firefighting shafts are common sources of building control queries.
The single most effective way to avoid building control fire safety queries is to have a fire engineer involved from the concept design stage, so that these issues are identified and resolved during design rather than after submission.
How to Address These Issues Before Submission
Each of these issues can be identified and resolved during the design process if the fire engineer is involved at an appropriate stage. Travel distance failures are resolved by adjusting floor plate layouts or providing compensatory measures such as enhanced detection or sprinkler protection. Staircase provision questions are resolved by designing the staircase configuration correctly from the outset. External wall compliance is addressed by specifying compliant materials at the specification stage.
For Gateway 2 submissions for higher-risk buildings, pre-application engagement with the BSR is strongly recommended for complex projects. The BSR's pre-application service allows the developer to discuss the proposed approach before formal submission and to identify any concerns that would prevent Gateway 2 from being passed.
Frequently Asked Questions
What is the most common fire safety issue raised by building control?
Travel distance non-compliance — escape corridor layouts that exceed the maximum distances permitted under the applicable code — is among the most frequently raised issues. It is also one of the most expensive to resolve at late design stages.
Can travel distance limits be exceeded with engineering justification?
In some cases, yes. Where enhanced fire safety measures — such as sprinklers, improved detection, or smoke control — are provided, performance-based analysis may demonstrate that travel distances in excess of the prescriptive limit are acceptable. This requires a robust engineering justification that the building control body must accept.
Does regulation 7(2) apply to all buildings over 18 metres?
Regulation 7(2) applies to all buildings with a storey at or above 18 metres in height. It restricts the use of combustible materials on the external walls of such buildings. All new buildings over 18 metres, and all significant refurbishments of existing buildings over 18 metres, must comply.
What information does building control need about fire doors?
Building control expects the fire strategy to reference a comprehensive fire door schedule, specifying the location, required fire resistance rating, leaf configuration, glazing, self-closing device, intumescent strip and smoke seal specification, and ironmongery for each fire door position in the building.
How long does it take for building control to assess a fire strategy?
For standard building control applications, the statutory period is 8 weeks. For Gateway 2 applications to the BSR, the statutory period is also 8 weeks, extendable for complex cases. Applications that are complete and well-prepared are more likely to be assessed within the statutory period.
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