How Fire Safety Statements Support Building Control Approval
A well-prepared fire safety statement can smooth the path to building control approval. Here's what building control bodies look for.
9 July 20244 min readFire Safety Services
How Fire Safety Statements Support Building Control Approval
A fire safety statement is a document submitted at planning stage to demonstrate that fire safety considerations have been addressed in the design of a proposed development. For higher-risk buildings, it is required as part of the Gateway 1 process under the Building Safety Act 2022. For major London applications, it is required under London Plan Policy D12a. At building control stage, the fire safety statement submitted at planning provides the foundation for the more detailed fire strategy that must be submitted for building control approval — but the two documents serve different purposes and are not interchangeable.
The Relationship Between the Planning Fire Statement and the Building Control Fire Strategy
The planning fire statement is a high-level document demonstrating that fire safety has been considered at concept design stage and that the proposed development can be built in a way consistent with fire safety requirements. It does not need to contain the level of technical detail required for building control approval. The building control fire strategy — developed at RIBA Stage 4 — is the detailed engineering document that demonstrates compliance with Part B of the Building Regulations in sufficient detail for the building control body to assess.
A well-produced planning fire statement sets out the fire safety concept clearly and establishes the framework for the building control fire strategy. Where the planning fire statement is consistent with the building control fire strategy, the transition from planning to building control is smoother and less likely to generate queries. Where there are significant inconsistencies — for example, if the building control fire strategy departs from the evacuation strategy or staircase configuration described at planning — both the planning and building control processes may need to be revisited.
Consistency between the planning fire statement and the building control fire strategy is important. A material change to the fire safety approach between planning and building control — such as a change in evacuation strategy or staircase configuration — may require a planning amendment before building control can be approved.
What Building Control Looks for in the Context of the Planning Fire Statement
Building control bodies reviewing the fire strategy for a development that had a planning fire statement will check for consistency between the two documents. The key areas of consistency include:
The evacuation strategy — stay put, simultaneous evacuation, or phased evacuation
The staircase configuration — number and position of escape staircases
The sprinkler provision — whether sprinklers are included and the design basis
The firefighting access and facilities — fire service vehicle access routes and firefighting shaft positions
The external wall approach — confirmation that external walls will comply with regulation 7(2)
London Plan Policy D12a and Building Control
For major applications in Greater London subject to London Plan Policy D12a, the GLA assesses the fire safety statement as part of the planning referral process. The GLA's requirements under D12a are sometimes more stringent than the national gateway process, particularly regarding the principle of single or dual staircase design and the documentation of the fire safety approach. Ensuring that the D12a statement is consistent with the intended building control fire strategy avoids issues at both stages.
Frequently Asked Questions
Is the fire safety statement submitted at planning the same as the fire strategy submitted at building control?
No. The planning fire statement is a high-level document demonstrating that fire safety has been considered at concept stage. The building control fire strategy is a detailed engineering document demonstrating compliance with Part B of the Building Regulations. They should be consistent but serve different purposes.
What happens if the building control fire strategy differs from the planning fire statement?
Material changes to the fire safety approach between planning and building control — particularly changes to evacuation strategy, staircase configuration, or sprinkler provision — may require a planning amendment. The fire engineer and architect should coordinate closely to ensure consistency.
Does the London Plan D12a fire statement affect building control?
Indirectly, yes. The GLA's assessment of the D12a statement at planning stage establishes the fire safety approach that is expected to be followed through to building control. Significant departures from the D12a approach at building control may require GLA re-engagement.
Can the same fire engineer produce both the planning fire statement and the building control fire strategy?
Yes — and this is often preferable, as the same engineer understands the design intent and can ensure consistency between the two documents. Continuity of fire engineering input from planning through building control reduces the risk of inconsistencies.
What if a fire safety statement was not submitted at planning?
For higher-risk buildings, a Gateway 1 fire statement is a requirement of the planning application. Where one was not submitted, this may need to be addressed retrospectively. For other buildings, the absence of a planning fire statement does not directly affect building control, but the building control fire strategy must still demonstrate compliance with Part B.
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