If you’ve been involved in a building project, a change of use application, or a significant refurbishment, you may have come across the term “fire strategy” and wondered whether it applies to you.
It’s a concept that isn’t always well understood outside of the construction and fire engineering professions, but for anyone responsible for a building of any complexity, it’s worth knowing what a fire strategy is, when one is required, and what happens if you don’t have one.
What is a Fire Strategy?
A fire strategy is a document that sets out how a building is designed, constructed, and managed to protect its occupants and the wider public in the event of a fire.
It describes the passive and active fire protection measures incorporated into the building, the assumptions made about how the building will be used and occupied, the means of escape and evacuation strategy, and the measures in place to limit the spread of fire and smoke.
A fire strategy is produced at the design stage of a new building or major refurbishment, typically by a fire engineer or suitably qualified fire safety consultant.
It informs the design decisions made by architects and engineers and forms part of the evidence submitted to demonstrate compliance with the Building Regulations 2010 (SI 2010/2214) — specifically Approved Document B, which sets out the functional requirements for fire safety in buildings in England.
It is important to understand that a fire strategy is not the same as a fire risk assessment.
Under Article 9 of the Regulatory Reform (Fire Safety) Order 2005 (SI 2005/1541), commonly referred to as the RRO, the Responsible Person for any non-domestic premises is required to carry out a suitable and sufficient fire risk assessment.
That is an operational document concerned with the day-to-day management of fire safety in an occupied building.
A fire strategy, by contrast, is a design document concerned with how the building itself has been built to resist, contain, and facilitate escape from fire.
The two documents are complementary, and in many cases, a fire risk assessor will want to see the fire strategy for a building in order to carry out a thorough and accurate assessment.
When is a Fire Strategy Required?
A fire strategy is typically required in the following circumstances.
For new buildings, a fire strategy will almost always be required as part of the Building Regulations approval process.
Regulation 11B of the Building Regulations 2010, as amended, requires that applications for building control approval are accompanied by sufficient information to demonstrate compliance with the applicable requirements.
Approved Document B sets out how those requirements can be met in relation to fire safety, and for anything beyond the simplest domestic structures, a fire strategy document forms a central part of that submission.
For material changes of use, Regulation 5 of the Building Regulations 2010 sets out the circumstances in which a material change of use triggers the need to demonstrate compliance with building regulations requirements, including those relating to fire safety.
If a building is being converted from one use class to another — for example, converting offices to residential flats, or a warehouse into a care home, a fire strategy will typically be required to demonstrate that the converted building meets the fire safety requirements appropriate to its new use.
This is an area where many building owners are caught out, particularly given the volume of office-to-residential conversions taking place under permitted development rights.
For significant refurbishments and extensions, Regulation 3 of the Building Regulations 2010 defines building work to which the regulations apply.
Where substantial structural or layout changes are being made to an existing building, a fire strategy review or update may be required, particularly if the changes affect means of escape, compartmentation, or the building’s fire protection systems.
For higher-risk buildings, the Building Safety Act 2022 (c.30) introduced a fundamentally new regulatory regime.
Section 65 of the Act defines a higher-risk building during occupation as a building in England that is at least 18 metres in height or has at least seven storeys, and contains at least two residential units.
For these buildings, the Principal Accountable Person is required under Section 88 of the Act to assess and manage building safety risks on an ongoing basis, and to produce and maintain a safety case report.
A fire strategy forms a fundamental part of that safety case. The Building Safety Regulator, established under Section 3 of the Act and operating within the Health and Safety Executive, has powers to require the production of this documentation and to take enforcement action where it is not in place.
For complex or non-standard buildings where compliance with Approved Document B cannot be demonstrated through standard prescriptive measures, because of a building’s size, layout, occupancy, or the nature of its use – a fire engineering approach may be required.
This involves producing a bespoke fire strategy that justifies alternative design solutions through quantitative or qualitative fire engineering analysis, in accordance with BS 7974:2019, the application of fire safety engineering principles to the design of buildings.
What if My Building Already Exists?
This is where many building owners and managers find themselves in uncertain territory.
For older buildings constructed before current Building Regulations came into force, or where the original fire strategy has been lost or never formally existed, there may be no readily accessible record of how the building was designed to perform in a fire.
This matters because the Responsible Person’s duties under the RRO are ongoing.
Article 17 of the Regulatory Reform (Fire Safety) Order 2005 requires the Responsible Person to ensure that the premises and any facilities, equipment, and devices provided in respect of fire safety are maintained in an efficient state, in efficient working order, and in good repair.
Without a clear understanding of how the building was designed to perform, its compartmentation strategy, the specification of its fire doors, the design basis of its alarm system, it is very difficult to demonstrate that this duty is being met.
In these circumstances, it may be necessary to commission a fire strategy review or to produce a fire strategy document for the existing building as it currently stands.
This involves a detailed assessment of the building’s construction, layout, occupancy, fire protection measures, and means of escape, and the production of a document that sets out how the building currently performs against relevant standards.
What About Residential Buildings?
The Fire Safety Act 2021 (c.24) clarified and extended the scope of the RRO to explicitly include the structure, external walls — including cladding, balconies, and windows, and flat entrance doors of multi-occupied residential buildings.
This brought a significant additional layer of responsibility to those managing residential blocks, and underlined the importance of understanding the fire strategy that underpins the building’s design.
The Fire Safety (England) Regulations 2022 (SI 2022/547), which came into force on 23rd January 2023, introduced further specific obligations for responsible persons in multi-occupied residential buildings.
For buildings over 11 metres in height, these include requirements around fire door inspections, the provision of fire safety instructions to residents, and the display of fire safety information in communal areas.
For buildings over 18 metres, additional obligations apply including the provision of information to the fire and rescue service, installation of wayfinding signage, and more extensive resident engagement requirements.
For those managing higher-risk residential buildings within the scope of the Building Safety Act 2022, the golden thread of building information, including the fire strategy, must be maintained and kept up to date throughout the life of the building under Section 91 of the Act.
What Should a Fire Strategy Include?
While the precise content will vary depending on building type, size, and use, a comprehensive fire strategy will typically address the following.
The scope, purpose, and assumptions underpinning the document. A description of the building including its construction, layout, height, use, and occupancy.
The passive fire protection measures incorporated into the building, including compartmentation, fire doors assessed in accordance with BS 8214:2016, and cavity barriers.
The active fire protection systems present, including fire detection and alarm systems designed to BS 5839, sprinkler or suppression systems designed to BS EN 12845, and smoke control systems.
The means of escape strategy, including travel distances, escape route widths, and protected stairwells, assessed against the guidance in Approved Document B.
The evacuation strategy — whether simultaneous, phased, or progressive horizontal evacuation, as informed by BS 9999:2017.
The facilities provided for the fire and rescue service, including vehicle access, rising mains, and firefighting lifts where required.
The ongoing management measures required to maintain the effectiveness of the fire strategy throughout the building’s lifetime.
Who Produces a Fire Strategy?
A fire strategy should be produced by a competent person with appropriate knowledge and experience of fire engineering and fire safety design.
For new buildings and major projects, this is typically a chartered fire engineer or specialist fire safety consultant, ideally a member of the Institution of Fire Engineers or a chartered member of the Institution of Engineering and Technology with a specialism in fire.
For existing buildings where a strategy review is needed, a suitably qualified fire risk assessor with experience of complex buildings may be able to assist, or may recommend engagement with a fire engineer for more technically demanding situations.
The Link Between Fire Strategy and Fire Risk Assessment
A fire strategy and a fire risk assessment are not interchangeable, but they are closely and fundamentally linked.
Article 9 of the RRO requires the fire risk assessment to consider the construction of the premises and the fire precautions provided within it.
A well-produced fire strategy provides the fire risk assessor with a clear baseline against which the current condition and management of the building can be assessed.
Conversely, a fire risk assessment that identifies significant deficiencies in passive or active fire protection may point to the need for a fire strategy review or update.
For building owners and managers, ensuring that both documents exist, are current, and are consistent with each other is an important part of demonstrating a robust and comprehensive approach to fire safety, and a strong basis for defence in the event of enforcement action or prosecution under the RRO.
We Can Help
At ESI: Fire Safety, we work with building owners, developers, managing agents, and facilities managers on fire safety across the full building lifecycle, from fire risk assessments and fire door inspections through to advising on fire strategy requirements and engaging with specialist fire engineers where needed.
If you’re unsure whether your building has an adequate fire strategy in place, or whether one is required for a project you’re planning, our team can help you understand your position and your options.
