The most frequent errors chartered fire engineers find when reviewing fire strategy reports — and how to avoid them.
23 July 20244 min readFire Safety Services
Why Fire Strategy Reports Fail
Fire strategy reports are rejected or queried by building control bodies and the Building Safety Regulator for a consistent set of reasons. Many of these failures reflect not a lack of technical knowledge but a lack of care, completeness, or appropriate application of the relevant standards to the specific building. Understanding the most common mistakes is the first step to avoiding them — and to identifying whether a fire strategy submitted for a project you are involved with is likely to pass regulatory scrutiny.
The Ten Most Common Fire Strategy Mistakes
1. Incomplete coverage of required topics — a fire strategy that addresses some but not all of the required fire safety elements. Missing sections on structural fire protection, external wall compliance, or firefighting facilities are particularly common. Building control will query anything that is absent.
2. Travel distance failures — escape route layouts where the travel distance from the furthest point on a floor to the nearest protected escape route or final exit exceeds the applicable limit. This is one of the most frequent and most expensive failures to resolve at late design stages.
3. Generic strategies not tailored to the building — a fire strategy that could have been written for any building of the same type, without reference to the specific characteristics of the project. Building control bodies recognise generic strategies and will query them.
4. Incorrect code selection — applying Approved Document B to a building where BS 9991 or BS 9999 is more appropriate, or applying the wrong sections of the applicable code to the building type. For example, applying residential code provisions to mixed-use buildings where commercial provisions are also relevant.
5. Unresolved sprinkler question — failing to clearly address whether sprinklers are required, or acknowledging that sprinklers are required but not specifying the design standard to which they will be provided.
6. External wall compliance not addressed — for buildings over 18 metres, failing to confirm that external wall materials comply with regulation 7(2) or to provide fire engineering justification for any derogations. This is increasingly a focus of BSR scrutiny at Gateway 2.
7. Performance-based departures without adequate justification — departing from prescriptive code requirements without the engineering analysis to support the departure. A statement that a departure is "acceptable" without evidence is not sufficient.
8. Inconsistency with drawings — a fire strategy that describes escape routes, compartment boundaries, or fire door positions that do not match the design drawings. Inconsistencies between the fire strategy and the plans are a common source of building control queries.
9. Outdated code references — referencing superseded standards or withdrawn guidance documents. Codes are updated regularly, and a fire strategy that relies on outdated references will be queried.
10. Produced by an insufficiently competent engineer — for higher-risk buildings, the BSR expects the lead fire engineer to hold Chartered Engineer status. A fire strategy produced by an engineer without the appropriate competence is unlikely to pass Gateway 2 scrutiny.
The most expensive fire strategy mistakes are those discovered late — at Gateway 2, during construction, or after completion. A peer review of the fire strategy by an independent chartered fire engineer before submission is a cost-effective way to identify and resolve these issues.
How to Avoid These Mistakes
The most reliable way to avoid fire strategy mistakes is to appoint a competent chartered fire engineer at an early stage of the project, to allow sufficient time for the strategy to be properly developed and reviewed before submission, and to ensure that the strategy is coordinated with the design drawings before it is submitted.
For complex projects, pre-submission engagement with the building control body or BSR is strongly recommended. For higher-risk buildings, independent peer review of the fire strategy by a second chartered fire engineer provides additional assurance and reduces the risk of Gateway 2 rejection.
Frequently Asked Questions
What is the most common reason a fire strategy fails at building control?
Incompleteness — missing sections, unexplained assumptions, or insufficient detail for the reviewer to assess compliance. Travel distance failures and unresolved sprinkler questions are also common.
Can a fire strategy be amended after submission?
Yes — building control will typically issue queries identifying deficiencies, and the fire engineer can submit a revised strategy in response. However, revisions that require design changes can cause significant programme delays.
What is peer review and when is it required?
Peer review is an independent assessment of a fire strategy by a second chartered fire engineer. It is required by the BSR for some complex or novel performance-based approaches and is strongly recommended for all Gateway 2 submissions for complex higher-risk buildings.
Does a fire strategy need to reference specific clause numbers in the applicable code?
A fire strategy should clearly identify the regulatory framework against which compliance is being demonstrated. Specific clause references are helpful for complex provisions but are not universally required. What is essential is that the strategy clearly demonstrates how the applicable requirements are met.
Who is responsible if a fire strategy is incorrect?
The fire engineer who produced the strategy carries professional responsibility for its technical content. The developer is responsible for ensuring that the appointed fire engineer has the appropriate competence and that the strategy is reviewed and coordinated with the design.
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