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Freelance journalist

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Ron Alalouff is a journalist specialising in the fire and security markets, and a former editor of websites and magazines in the same fields.
April 6, 2022

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Building safety

Mayor’s fire safety plan for London aims to exceed national building regulations

In his draft guidance on fire safety, the Mayor of London is seeking to ensure the highest standards of fire safety from the earliest design stages. Ron Alalouff investigates the details of the proposals.

The guidance sets out how developers should demonstrate compliance with the Mayor’s detailed London Plan policies to achieve “the highest standards in fire safety and safe and dignified evacuations”. This is in addition to the Government’s fire safety considerations that apply only to a limited number of buildings at the planning application stage.


Mayor of London, Sadiq Khan

The guidance says that fire safety needs to be considered from the outset to ensure best outcomes for occupants and users. The evolution of a fire safety strategy and evacuation strategy is iterative, progressing alongside the detailed design of the development and understanding of how it will be used and occupied.

The guidance sets out how applicants demonstrate compliance with London Plan policies D12 and D5 (B5). As planning officers are not experts in fire safety, it says, the onus is on the applicant to ensure that they use the necessary fire safety expertise to demonstrate compliance with these policies.

The guidance supports the concept of the ‘golden thread’, whereby fire safety information on a building is collected and maintained through its whole life. The information should be maintained and updated as the design evolves, as well as throughout the construction and occupation phases.

While the government’s system of fire safety gateways requires fire safety information for relevant buildings to be submitted to the regulator, in comparison to Gateway One, the London Plan policy D12 applies to all land uses and to a lower size threshold, and requires a greater number of fire safety elements to be demonstrated as part of a planning application. Section 2.1.4 says:

“Given the London Plan requires more information than that set out in Gateway One, as well as the intrinsic link between fire safety, design and the evacuation strategy, it is essential that applicants submit fire safety information in line with the requirements in this LPG, as well as complying with the government’s fire safety gateways.”

Holistic approach to fire safety

The draft Policy D12(A) says that at the early design stages, developers should take a holistic approach to fire safety which considers location, land use, occupancy, operation of the building, construction methods, materials, the Building Regulations, passive and active fire safety measures, and management, to inform the most appropriate fire safety strategy for the development. The measures required during the construction and management stages of a development also need to be fully considered at the early design stage. Early consideration of fire safety can obviate the need to redesign a scheme at Building Regulations stage, where changes can lead to inappropriate fire safety solutions.

The fire safety information provided at the planning application stage should be developed to inform the overall fire safety strategy for the development. In passing on fire safety information to subsequent development stages, consideration should be given to the accessibility, accuracy and relevance of the information to ensure the development is constructed as it has been designed and originally specified. A handover process for the fire strategy to the building owner should also be identified.

The planning fire safety strategy should include:

  • A statement that sets out who has written and approved the fire safety information and their competence (relevant qualifications and experience), commensurate with the size, scope and complexity of the development
  • Information under each criteria of Policy D12(A)
  • The relevant fire safety design code/s and standards, and how these ensure the proposed development achieves the highest standards of fire safety, proportionate to the size and nature of the development.

The fire statement should set out:

  • How the proposed fire safety measures meet the requirements of London Plan Policy D12B
  • How evacuation lifts have been incorporated into the development
  • How the development meets the minimum fire safety regulations and standards
  • What additional fire safety measures are to be included beyond the minimum requirements of the Building Regulations
  • Whether a Planning Gateway One fire statement has also been submitted.

In respect of the building’s construction methods, products and materials used, the fire statement should:

  • Specify the proposed construction method of the development
  • Identify the construction methods that could impact on the fire safety of adjoining units, neighbouring sites, buildings and occupants
  • Identify suitable fire control measures, where the proposed construction methods pose a high risk of fire (cross referenced with active and passive fire safety measures)
  • Identify suitable fire control measures to reduce the risk of and limit any impact of a fire within the proposed development on the surrounding area.

Also set out should be the class of fire resistance the various elements of the development are to achieve, and how this informs the overall design and fire safety strategy. This information will support the ‘golden thread’ to ensure that the design criteria – including the proposed construction method and performance of materials – is followed in the construction phase. This would also ensure that changes to materials can be identified by all parties and any required mitigation measures implemented to ensure the highest standard in fire safety. The fire statement must include a commitment that the development will not incorporate combustible materials in its external walls.

Fire evacuation strategy

In relation to the evacuation strategy, the fire statement should justify whether simultaneous evacuation has been considered and whether the proposed stair cores would allow for this, and if a stay-put strategy is proposed, what mitigations are included should occupants decide to self-evacuate. The fire statement should also set out the passive and active fire safety measures that have been considered, and to which regulations, standards and codes they have been designed to; access and facilities to and within the site for the fire and rescue service; and how the fire strategy and protective measures would be retained and not be compromised. As a minimum, the fire statement should identify the elements of the building that, if modified, may adversely affect the original fire safety strategy.

There are no minimum qualification requirements for the author of a planning fire safety strategy, but they should have a suitable fire safety background with the appropriate knowledge, understanding and qualifications commensurate with the size, scope and complexity of the proposed development. For major developments, a registered fire engineer is required to write the planning fire safety strategy and fire statement, as set out in Policy D12(B). For larger and more complex schemes, it is also recommended the author is a registered fire engineer, and for smaller schemes, the author should justify their competency to write the planning fire safety strategy.

The guidance on policy criteria for policy D12(A) include:

  • The identification of suitably positioned unobstructed outside space for fire appliances to be positioned on, and a space appropriate for use as an evacuation assembly point
  • The incorporation of appropriate features which reduce the risk to life and serious injury in the event of a fire, including appropriate fire alarm systems and passive and active fire safety measures
  • The planning fire safety strategy should detail how the construction methods of the development are appropriate to minimise the risk of fire spread
  • The provision of suitable and convenient means of escape and an associated evacuation strategy for all building users. The proposed means of escape will inform the evacuation strategy, which must be inclusive and appropriate for people with disabilities – including mobility, sensory and cognitive disabilities – and those who may not speak or understand English.
  • The provision of suitable access and equipment for firefighting appropriate for the size and use of the development. Access for the fire and rescue service and firefighting facilities may be provided in line with Approved Document B as a minimum standard, but measures must be specific and relevant to the proposed development.

Evacuation lifts

The guidance also seeks to ensure that evacuation lifts – and the space and measures for them to operate – are included in developments “so that people can evacuate a building with dignity during an emergency”. Policy D5(B5) states that in all developments where lifts are installed, a minimum of at least one lift per core should be a suitably sized fire evacuation lift, suitable to be used to evacuate people who require level access from the building. Evacuation lifts should be provided in addition to Building Regulations requirements for firefighting shafts/lifts, to ensure they can be used for evacuation purposes when the firefighting lift is being used by the fire and rescue service.

All building users should be able to evacuate with dignity and by as independent means as possible. Emergency carry down or carry up mechanical devices ­– or similar interventions that rely on manual handling ­– are not considered appropriate, for reasons of user dignity and independence. The installation of evacuation lifts (accompanied by a management plan) provide a dignified and more independent solution.

Launching the guidance consultation, the Mayor of London, Sadiq Khan, said: “The current building safety situation is a scandal and I am concerned that almost five years after the tragedy at Grenfell Tower, it appears that the government are still not willing to properly address it. That’s why I’ve been using all the tools at my disposal to raise the standard of fire safety measures in London, through requirements for developers in my London Plan, and lobbying developers and building owners to share vital fire safety information with residents.

“This draft guidance goes even further and will ensure fire safety is embedded in the earliest stage of the design process.

“Ministers must do their part and urgently review and improve Building Regulations, including regulations relating to single escape staircases in very tall buildings.”


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