How Fire Strategies Support Building Safety Act Compliance
The Building Safety Act 2022 has fundamentally changed what is required from fire strategies for higher-risk buildings.
11 March 20254 min readFire Safety Services
How the Building Safety Act Changed Fire Strategy Requirements
The Building Safety Act 2022 fundamentally changed what is required from fire strategies for higher-risk buildings — those over 18 metres in height or more than seven storeys containing at least two residential units. The Act introduced the Building Safety Regulator as the new regulatory authority for these buildings, replacing the previous system of local authority building control and approved inspectors. With that change came significantly more rigorous requirements for fire safety documentation at every stage of a building's life.
Fire Strategies at Gateway 1 (Planning)
Gateway 1 is the first regulatory checkpoint in the Building Safety Act's gateway process. Before a planning application for a higher-risk building can be approved, a fire statement must be submitted demonstrating that fire safety considerations have been addressed at concept design stage.
The Gateway 1 fire statement must address fire service vehicle access and facilities, the high-level escape strategy, the principle of compartmentation, and confirmation that the proposed development can be built in a way consistent with Part B of the Building Regulations. The Health and Safety Executive is a statutory consultee on Gateway 1 applications and will raise concerns where the fire safety information is inadequate.
Fire Strategies at Gateway 2 (Pre-Construction)
Gateway 2 is the most significant new requirement introduced by the Building Safety Act for fire engineers. Before construction of a higher-risk building can commence, the developer must submit a detailed building regulations application to the Building Safety Regulator and receive approval. The BSR will not pass Gateway 2 without a comprehensive fire strategy.
The Gateway 2 fire strategy must go significantly beyond what was previously submitted to building control. It must address:
A detailed escape strategy including staircase configuration, corridor and lobby layouts, travel distances, and evacuation strategy
Fire compartmentation specifications — compartment wall and floor construction, fire resistance periods, fire door schedules
External wall fire safety — confirmation that external wall materials comply with regulation 7(2) for buildings over 18 metres, or fire engineering justification for any derogations
Fire detection and alarm system design basis
Sprinkler system requirement and design basis under BS 9251 or LPC rules
Smoke control strategy and equipment specifications
The BSR has a statutory 8-week period to assess Gateway 2 applications, extendable in complex cases. The clock does not start until all required information — including the fire strategy — is submitted. Incomplete submissions will be rejected and the clock restarted.
Fire Strategies at Gateway 3 (Completion)
Gateway 3 is the completion checkpoint. Before a higher-risk building can be occupied, the developer must submit as-built information to the BSR and receive a completion certificate. The fire strategy must be updated to reflect any changes made during construction — commonly known as the as-built fire strategy.
The as-built fire strategy forms the foundation of the golden thread of building information that the accountable person must maintain throughout the building's occupation. It must accurately reflect the building as constructed, not the design intent, and must be kept up to date as the building is altered or its fire safety systems are modified.
Fire Strategies During Occupation
The Building Safety Act's requirements do not end at handover. During occupation, the accountable person must maintain the building safety case, which includes the fire strategy as a core document. The fire strategy must be reviewed whenever significant changes are made to the building and must be updated to reflect those changes. The BSR can require the accountable person to submit the building safety case for assessment at any time.
Frequently Asked Questions
Does the Building Safety Act apply to my building?
The Act applies directly to higher-risk buildings — those over 18 metres or seven storeys with at least two residential units. If your building meets this definition, you must comply with the gateway process for new buildings and registration and building safety case requirements for existing buildings.
What is the difference between the old building control process and Gateway 2?
Under the old system, building control could be carried out by local authorities or approved inspectors with relatively limited scrutiny of fire safety documentation. Gateway 2 requires submission to the Building Safety Regulator, which applies a more rigorous review process and will not approve construction until all fire safety information meets the required standard.
How long does Gateway 2 take?
The BSR has a statutory 8-week assessment period for Gateway 2 applications, extendable for complex cases. In practice, applications that are incomplete or contain inadequate fire safety information will be returned, restarting the clock. Well-prepared applications with comprehensive fire strategies are more likely to pass without significant delay.
What happens if the fire strategy changes during construction?
Changes to the fire strategy during construction must be assessed to determine whether they require BSR notification or approval. Significant changes that affect the fundamental fire safety provisions — escape routes, compartmentation, sprinkler coverage — will typically require BSR notification. All changes must be reflected in the as-built fire strategy at Gateway 3.
Who is responsible for maintaining the fire strategy during occupation?
The accountable person — or principal accountable person for buildings with multiple accountable persons — is responsible for maintaining the building safety case, which includes the fire strategy. This responsibility cannot be delegated away, though it can be supported by specialist consultants.
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