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NFCC pinpoints concerns over Government consultations on building safety

19 October 2022

THE NATIONAL Fire Chiefs Council (NFCC) has responded to the Department for Levelling Up, Housing and Communities’ building safety reform consultations. These key consultations, which closed on Wednesday 12 October, lay out the principles that will determine what the new building safety regime is going to look like during construction and occupation phases.

The NFCC has “raised concern” about the lack of clarity and detail on some of the issues within the consultations. These concerns “need urgent attention and clarification”, suggests the NFCC, before the regime goes live next year.

Further, the NFCC has called on the Government to ensure that comments made by the Fire and Rescue Service on new buildings do not “continue to be ignored” by those receiving them.

Gavin Tomlinson, chair of the NFCC’s Protection Scrutiny Committee, noted: “Currently, there is no requirement on the applicant or the Building Control body to satisfy the Fire and Rescue Service comments. If the advice given by the Fire and Rescue Service during construction is listened to and acted upon, this can help to ensure buildings are more easily able to meet the safety case requirements within occupation. At present, building design is not linked to management of the building once occupied. Therefore, the needs of those living within the building are not taken into account.”

Tomlinson added: “We believe that treating Building Regulations holistically with management of the building will help mitigate cases where costly Personal Emergency Evacuation Plans are being considered as a solution to compensate for failings and out-of-date guidance in the built environment.”

In-occupation safety

Nick Coombe, head of the NFCC’s Protection and Policy Reform Unit, observed: “The rules for how buildings are allowed to be built in the first instance, including their evacuation features, are overseen by the Department for Levelling Up, Housing and Communities. At present, it’s still possible to design a building using an approved guidance that may not meet the requirements of safety for the in-occupation stage of the new system. Examples include the use of guidance to design tall single staircase buildings with no provision for evacuation facilities for the disabled.”

Coombe went on to comment: The NFCC would like to see clearer guidance on how the evacuation needs of disabled people and persons who may find themselves in vulnerable positions will be regulated as part of the new regime. We have seen through the evidence given to the Grenfell Tower Public Inquiry, as well as Home Office consultations, just how challenging the issue of evacuation is in single staircase buildings and yet the current system continues to allow around 400 of these new buildings to be built every year. In light of how many other countries require multiple stairs in tall buildings, this position must be reviewed.”

Further, Coombe asserted: “Without mechanisms to compel physical solutions in buildings, either before or after they are built, we know – and have seen – that duty holders are likely to rely on far less effective management solutions to cover shortfalls in safety.”

In conclusion, Coombe explained: “We have concerns that some of the proposals within the consultations reinforce the current regime and status quo. In our view, this does not support the policy intent of creating a new and strengthened building safety regime.”

*The NFCC’s full submissions to the following consultations can be viewed online by accessing the following links:

Implementing the new building control regime for higher-risk buildings and wider changes to the Building Regulations for all buildings

New safety regime for occupied higher-risk buildings