Fire Safety Statements for Gateway 2 Applications

Fire Safety at Gateway 2: What the BSR Requires

Gateway 2 is the most significant regulatory checkpoint in the Building Safety Act 2022's gateway process for higher-risk buildings. It is the point at which the Building Safety Regulator must approve the building's fire and structural safety design before construction can commence. No higher-risk building may legally begin construction without a Gateway 2 approval — and the BSR will not issue that approval without comprehensive fire safety documentation, including a detailed fire strategy.

What Is Required at Gateway 2

The Gateway 2 application to the BSR must include the following fire safety documentation:

• Full fire strategy report — a comprehensive technical document addressing all aspects of the building's fire safety design: escape strategy and means of escape, compartmentation, structural fire protection, fire detection and alarm, sprinkler systems, smoke control, and firefighting facilities
• External wall fire safety statement — for buildings over 18 metres, explicit confirmation that the external wall specification complies with regulation 7(2), or a fire engineering justification for any derogations
• Fire door schedule — a comprehensive schedule of all fire doors in the building, with locations, fire resistance ratings, and specifications
• Sprinkler design basis — where sprinklers are required, the design basis document setting out the design standard, system type, and coverage
• Smoke control strategy — the smoke control design basis and, where performance-based analysis has been used, supporting CFD modelling reports
• Consistency with planning documentation — confirmation that the Gateway 2 fire safety approach is consistent with the Gateway 1 fire statement submitted at planning, or explanation of any material changes

BSR Assessment Process and Common Queries

The BSR assesses Gateway 2 applications against the requirements of the Building Regulations and the Building Safety Act 2022. Common queries raised by the BSR include:

• Staircase configuration — whether the proposed number and arrangement of staircases is adequate for the building's height, floor area, and occupancy
• External wall compliance — whether the proposed external wall specification complies with regulation 7(2), and the evidence supporting that conclusion
• Performance-based approaches — where the fire strategy departs from prescriptive requirements, the BSR will scrutinise the engineering justification closely and may require peer review
• Fire engineer competence — for complex higher-risk buildings, the BSR may request confirmation of the lead fire engineer's qualifications and relevant experience

Pre-Application Engagement with the BSR

The BSR offers pre-application services for Gateway 2, allowing developers to discuss their proposed approach before formal submission. For complex higher-risk buildings, taking advantage of this service is strongly recommended. Pre-application engagement allows the BSR to identify any fundamental concerns with the proposed fire safety approach before the formal application is submitted, reducing the risk of queries and delays at Gateway 2.

After Gateway 2: Managing Changes During Construction

Once Gateway 2 has been passed, changes to the fire safety design during construction must be carefully managed. Changes that materially affect the fire safety provisions — escape routes, compartmentation, external wall specification, sprinkler coverage — must be notified to the BSR and may require a revised submission and new approval before the works can proceed. The fire engineer must remain engaged throughout construction to assess the fire safety implications of proposed changes and to advise on whether BSR notification is required.