Planning fire statements are required for a growing range of development types. Here's everything you need to know about what they cover and when they're needed.
7 January 20254 min readFire Safety Services
What Is a Fire Safety Statement?
A fire safety statement is a document submitted as part of a planning application to demonstrate that fire safety considerations have been addressed in the design of a proposed development. It is required for certain categories of planning application under national planning policy and — for applications in Greater London — under London Plan Policy D12a.
A fire safety statement is not the same as a full fire strategy report. It is a higher-level document that demonstrates fire safety has been considered in the design concept, that the development can be built in a way consistent with fire safety requirements, and that fire service vehicle access and facilities can be achieved. The detailed fire engineering is carried out at the building control stage.
When Is a Fire Safety Statement Required?
At national level, a fire statement is required as part of the Gateway 1 process under the Building Safety Act 2022 for higher-risk buildings — those over 18 metres in height or more than seven storeys, containing at least two residential units. This requirement applies to planning applications submitted to local planning authorities across England.
In Greater London, the requirements are broader. London Plan Policy D12a requires a fire safety statement to be submitted with planning applications for:
Any development involving a building of ten storeys or more
Any development that would result in a building classified as higher risk under the Building Safety Act 2022
Applications referred to the GLA as a major development
Note for London applications: London Plan Policy D12a applies to applications for ten storeys or more — lower than the 18-metre threshold for Gateway 1. Developers in London should assume a fire safety statement is required for any tall or complex residential development.
What Does a Fire Safety Statement Need to Cover?
A fire safety statement submitted for Gateway 1 must address:
Fire service access — vehicle access routes, turning areas, hardstanding, and fire service facilities including dry risers and firefighting lifts
Means of escape — a high-level description of the escape strategy, confirming that compliant means of escape can be achieved within the proposed design
Fire safety design approach — confirmation that the development will be designed in accordance with Approved Document B, BS 9991, BS 9999 or other applicable standards
External fire spread — confirmation that external wall materials will meet the requirements of Approved Document B regulation 7(2) for buildings above 18 metres
Consultation with the fire service — confirmation that the proposals are consistent with fire service requirements, which may require pre-application consultation with the relevant fire and rescue service
For London Plan D12a applications, the statement must also demonstrate that the development prioritises the safety of occupants through the design, and that the principles of the National Fire Chiefs Council (NFCC) guidance have been considered.
Who Produces a Fire Safety Statement?
A fire safety statement must be produced by a suitably qualified fire engineer. For Gateway 1 applications and London Plan D12a applications, the fire engineer should have relevant experience of tall and complex residential buildings and should ideally hold Chartered Engineer (CEng) status.
A fire safety statement should not be produced by the architect or developer without fire engineering input. Planning authorities and the GLA are increasingly scrutinising fire safety statements and will reject applications where the fire safety information is inadequate or superficial.
What Happens After Planning Approval?
The fire safety statement submitted at planning stage is a high-level document. Following planning approval, the developer must commission a full fire strategy report to be submitted as part of the Gateway 2 application to the Building Safety Regulator. The Gateway 2 fire strategy builds on the principles established in the planning fire safety statement but is a substantially more detailed engineering document.
Frequently Asked Questions
Is a fire safety statement the same as a fire strategy report?
No. A fire safety statement is a planning document demonstrating that fire safety has been considered at concept design stage. A fire strategy report is a detailed engineering document submitted at building control stage. Both are required for higher-risk buildings, at different stages of the project.
Does London Plan Policy D12a apply to all planning applications in London?
No — Policy D12a applies to development involving buildings of ten or more storeys, or buildings that would be classified as higher risk under the Building Safety Act 2022, and to applications referred to the GLA. Standard low-rise residential applications are not affected.
Who reviews the fire safety statement at Gateway 1?
The local planning authority reviews the fire safety statement as part of the planning application. For Gateway 1 higher-risk buildings, the Health and Safety Executive (which hosts the Building Safety Regulator) is a statutory consultee on the planning application.
Can an architect write the fire safety statement?
The fire safety statement must be produced by or with the direct input of a suitably qualified fire engineer. A statement written solely by the architect without fire engineering input is unlikely to satisfy planning authorities, particularly for higher-risk buildings.
What happens if a fire safety statement is rejected at Gateway 1?
If the fire safety statement does not satisfy the planning authority or the BSR as statutory consultee, the planning application may be refused, or conditions may be imposed requiring revision of the fire safety information before development can commence.
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