The built environment accounts for circa 37% of UK carbon emissions and nearly 50% of all material resource use. Fire safety plays a critical role within this landscape, influencing product choices, system design, construction methods and whole-life building performance.

As regulatory and market expectations accelerate, the FIA’s Sustainability Special Interest Group will provide a dedicated forum for members to collaborate on practical, proportionate and credible approaches to sustainability.

Key focus areas

The Special Interest Group will bring together manufacturers, service providers and sustainability specialists in order to address both environmental and social aspects of sustainability, including Environmental Product Declarations and Life Cycle Assessments, embodied carbon and ‘Net Zero’ pathways, circular economy principles and product lifecycles, Environmental, Social and Governance reporting and practical tools and social sustainability topics such as diversity and inclusion, well-being and community impact.

The Special Interest Group will share practical guidance, real-world Case Studies and tools that members can apply immediately within their organisations, helping to move beyond compliance towards Best Practice.

Supporting members

Sustainability-related requirements across the built environment are evolving rapidly. From the Future Homes and Buildings Standard (2025) to Construction Products Regulation updates, Digital Product Passports and embodied carbon disclosure, requirements are accelerating.

The FIA’s Sustainability Special Interest Group will help members to stay ahead, with practical guidance, peer insights and aligned approaches with UKGBC (the UK’s Green Building Council), the Building Research Establishment and the Alliance for Sustainable Building Products.

Registering interest

FIA members and non-members alike are invited to register their interest in joining the founding cohort of the FIA’s Sustainability Special Interest Group and help set the agenda for sustainable fire safety.

Interested parties should send an e-mail to [email protected]

The Special Interest Group’s first meeting takes place on Friday 20 February.

Ultimately, the FIA’s Sustainability Special Interest Group aims to support a fire safety sector that not only protects lives and property, but also contributes positively towards a safer, lower carbon and more socially responsible built environment.

Fire protection contractors, installers and engineers right across the country will now have access to high-quality Italian fire pump solutions, along with dedicated customer service courtesy of a knowledgeable UK-based team.

Idroelettrica is renowned for its ongoing commitment to quality and precision in the manufacture of fire pump sets and pump house equipment. The business offers cost-effective bespoke solutions and options that meet a wide range of international, European and British industry standards. The recent expansion of its manufacturing and in-house testing facilities in Modena ensures swift delivery times along with robust quality control.

Growing demand  

The launch of Millars Pumps responds to a growing demand for reliable fire pump solutions in both new-build and retrofit projects across the UK, driven by stricter fire safety standards and planning requirements.

As the management teams at more commercial sites and high-rise residential buildings determine to upgrade or install sprinkler, water mist and hydrant systems, Millars Pumps will support contractors and specifiers with compliant, reliable and space-efficient equipment.

Along with its wide range of end suction, split case, vertical turbine and submersible pumps and associated equipment, Millars Pumps will introduce Firebox. Idroelettrica’s flagship solution, Firebox is a ‘plug-and-play’ pre-fabricated pump room, which arrives complete and ready to install.

An efficient and cost-effective alternative to constructing a traditional pump house, Firebox is fully customisable to clients’ specifications and space requirements. The innovative design means that all sides can fully open, providing 360° access for easy maintenance, inspection or future upgrades.

Combined expertise

Giovanni Vaccari, sales export manager at Idroelettrica Spa, informed Fire Safety Matters: “The launch of Millars Pumps in the UK is exciting news for any company looking to install or upgrade fire pumps for sprinkler or water mist fire protection systems. Products in our wide range of fire pump solutions, which encompasses Firebox, are designed to be long-lasting, convenient to install and easy to maintain.”

Vaccari concluded: “The combined expertise of Millars Pumps and Idroelettrica will ensure UK customers are fully supported at every stage of the process, from specification all the way through to delivery, installation and maintenance.”

*Further information is available online at www.millarspumps.co.uk

The British Standard was updated in the wake of the Grenfell Tower tragedy and subsequent fire safety reforms and aims to improve consistency, quality and accountability in terms of how fire risk assessments are conducted.

Fire risk assessments are a legal requirement in the UK. Anyone who’s responsible for a building – for example an employer, an owner or the occupier of a premises that isn’t a ‘single private dwelling’ (ie a private home) – needs to make sure that a suitably competent individual completes this process.

SFJ Awards has worked with Fire and Rescue Services, the Ministry of Defence and others to develop the Ofqual-regulated Level 4 Certificate and Level 4 Diploma in Fire Risk Assessment qualification routes in order to offer greater flexibility for learners.

The qualifications support the application of legislation and risk-based methods across a range of premises, enabling learners to produce clear findings and recommendations as part of the fire risk assessment process.

Learning architecture

David Higham, managing director at SFJ Awards, commented: “Delivering improved standards in fire risk assessments relies upon having the learning architecture in place to support learners so that they can acquire the requisite knowledge and apply it practically in the field. Bringing these new qualifications to market is a key step forward in supporting this aim and enabling alignment with BS 8674:2025.”

Higham continued: “The introduction of the Level 4 Certificate and Level 4 Diploma brings forward two qualification routes to provide flexibility for learners and support greater coverage across the sector, as is needed, in order to drive up safety standards overall.”

Chris Wilson is managing director at The Fire Safety Academy and was part of the Steering Group that led on the development of the qualifications. “BS 8674:2025 is an important step forward for assessing and mitigating fire risk in residential complexes, tall buildings and business in addition to mixed-use premises across the UK. The qualifications provide a vital bridge between the new safety standards and learners and practitioners responsible for conducting fire risk assessments.”

Continuing Professional Development

The Level 4 Certificate and Level 4 Diploma in Fire Risk Assessment are now available for delivery at Training Centres across the UK and support progression through supervised practice, workplace experience and ongoing Continuing Professional Development.

The Level 5 Certificate and Diploma in Fire Risk Assessment are also in development to support progression to the advanced fire risk assessor competencies outlined in BS 8674:2025.

*Further information is available online at https://sfjawards.com/qualifications/fire-and-rescue/certificate-diploma-in-fire-risk-assessment

BS 8524 remains the leading reference point for the design, specification, testing, application, installation and maintenance of active fire curtain assemblies in the UK.

The series comprises two parts: Part 1 (Product Specifications and Performance Requirements) and Part 2 (Code of Practice for Application, Installation, Commissioning and Maintenance). Both parts have been republished for the 2025 iteration.

A major challenge for industry compliance has been the lack of UKAS-accredited third party certification schemes, following the withdrawal of previous bodies in 2023. The Association for Specialist Fire Protection (ASFP) is pleased to note that UL has now achieved UKAS accreditation to certify products to BS 8524 and is accepting new applications: an important step in supporting consistent and independent verification of product performance.

Debate has continued regarding the interaction between BS 8524-1 and the harmonised European Standard EN 16034, which is also designated in the UK as BS EN 16034. The work conducted in redrafting the BS 8524 series of standards addressed the scope clash and sought to differentiate applications where the different standards are appropriate.

BS 8524 includes unique and more stringent testing requirements – notably cycle and independent ‘hot’ motor testing – that are not covered within EN 16034, except in specific cases such as pedestrian door set applications as installed in Shopping Centres, where the EN standard is a legal requirement.

The revised BS 8524 also references ISO 21524, the new international standard concentrated on fire curtains. This includes updated test methods addressing features such as vision panels, thereby ensuring stronger alignment between UK practice and global standards.

BS 8524-1:2025 – scope and application

BS 8524-1:2025 addresses performance criteria including reliability and durability, fire resistance, smoke containment, force-gauge resistance and the performance of control devices and ancillary equipment.

The British Standard applies to active fire curtain barrier assemblies made of any material and intended to provide fire resistance in most end-use applications. It doesn’t apply to barriers forming part of a building’s structure, theatre/proscenium textile curtains (see BS 5867-1), fabrics for curtains, drapes and blinds (see BS 5867-1 and BS 5867-2), smoke barriers (see BS EN 12101-1) or operable fabric curtains used in retail settings for pedestrian access (see BS EN 16034).

Mike Ward, managing director at the ASFP, commented: “The release of the 2025 versions of the BS 8524 series marks a pivotal moment for the fire safety sector. After a prolonged period of confusion and inconsistency, the industry now has a clear and robust framework for the specification and testing of active fire curtain barriers.”

Ward added: “This update strengthens alignment with international standards, restores a vital third party certification pathway and provides the clarity that manufacturers, installers, regulators and, ultimately, end users have urgently needed. The ASFP strongly welcomes this revision and encourages all stakeholders to adopt and apply the updated requirements without delay.”

*Further information is available online at www.bsigroup.com and www.asfp.org.uk

This will be the first dedicated Emergency Lighting qualification offered by the FIA, providing learners with a formally recognised outcome on successful completion. Moving to FireQual accreditation ensures the course meets nationally recognised assessment and quality standards, strengthening confidence in both the training and the competence of those who complete it.

The introduction of a Level 3 FireQual qualification reflects the continued professionalisation of fire industry training. By combining structured learning with an independent examination, the updated Emergency Lighting course demonstrates how industry training standards are evolving to meet increasing expectations around competence, compliance and accountability.

The qualification also aligns with the BAFE Emergency Lighting Scheme, duly supporting organisations and individuals working within third party certification frameworks.

All Emergency Lighting courses delivered from 2026 onwards will follow the new Level 3 FireQual format.

*For additional information on this course and the full range of FIA training opportunities visit www.fia.uk.com/training/training-course-browser.html

Gateway 2 determinations continue to rise, with 347 decisions across all application types in the 12 weeks to 22 December (totalling 727 since 29 September 2025).

The final quarter of 2025 will see the highest number of decisions since the Building Safety Regulator commenced operations, with a likely total of more than 700 by 31 December compared to just over 200 in Q1. That represents a potential 250%-plus increase.

The number of live applications of all categories now shows a downward trend, reducing from 1,219 to 1,158 over the past 12 weeks.

69% of all decisions across all categories during December related to London cases, making it 503 decisions since 29 September in the capital: the highest number of determinations in London since the Building Safety Regulator began operations.

Recently, the Building Safety Regulator also published guidance on staged applications and the criteria for validating, approving or rejecting applications. 

These updates are part of the improvements being made to ensure applications can be processed more efficiently and to support industry in submitting high-quality Building Control applications.

Innovation Unit progress

The Innovation Unit – itself a dedicated team of registered building inspectors, technical engineers and regulatory leads – has made three approvals to date within 12 weeks, with another four approvals expected by 31 December.  

For cases which are over 12 weeks, but are likely to be approved if further information is supplied, the Building Safety Regulator is adopting a pragmatic approach. Account managers have been assigned to liaise closely with the applicants to give these cases the best opportunity to progress.

The Innovation Unit is currently managing 102 live new build applications representing 24,624 units.

Times to validate and reject any incomplete applications are also much quicker than under the previous model, which enables applicants to quickly address issues and resubmit.

Resolving historical cases

54 complex historic applications submitted under the previous model have been closed since 29 September, with 30 of these recent decisions relating to London cases. Another four cases are likely to be decided by 31 December.

The Building Safety Regulator’s operational team’s direct engagement with applicants and regulatory partners, along with addressing individual ‘blockers’. is resulting in these historic complex cases being closed at a significant rate.

Remaining legacy applications are the Building Safety Regulator’s key focus in the New Year with face-to-face meetings continuing with regulatory partners and applicants in January. This is part of a pragmatic approach towards dealing with complex or contested applications rather than these cases being rejected without any intervention.

The Building Safety Regulator is also continuing to implement its batching process launched in September. This new pilot process scales capacity by bundling applications to specialised engineering services suppliers for accelerated assessment with a regulatory lead officer providing oversight and remaining the decision-maker.

New remediation cases

Open remediation cases have held steady, with 82 decisions made since 29 September and 83 new cases received. 280 lives cases are now being processed.

The Building Safety Regulator’s focus is on closing older applications, which typically don’t have sufficient detail for a decision and so require significant liaison with applicants to move to a successful conclusion.

In parallel, the Building Safety Regulator is also prioritising higher-risk projects and those with funding constraints. Several remediation cases are now in the batching process and progressing more quickly than with the previous model.

Established momentum

Charlie Pugsley, CEO of the Building Safety Regulator, commented: “The immediate and positive results we saw from our pilot operational changes are now firmly established across the Building Safety Regulator and show a clear path to continued success. We have made the most determinations in our operating history, cleared significant numbers of our complex historic cases by engaging with applicants, as well as publishing guidance on staged applications and continuing to build upon the work of our Innovation Unit.”

Pugsley continued: “Across the Building Safety Regulator, and we believe within the industry, there’s now a confidence we can continue to make more decisions at an increasing pace through our new processes and by engaging appropriately with applicants. Rightly, we continue to remain cautiously optimistic as we know the pace of improvements must continue into 2026 and beyond.”  

In conclusion, Pugsley noted: “We all remain fully committed to supporting the pace of essential construction, while upholding the critical safety standards in place to keep thousands of people safe in both new and existing homes.”

*Building Control Approval Application Data to 22 December 2025

It emerges that 1,338 relevant buildings (ie 71.7%) are expected to be remediated within the next five years. Of the 2,641 buildings identified as having life-critical fire safety defects since June 2017, 932 have been remediated (or are completed awaiting a new building works assessment).

The Regulator of Social Housing will continue to monitor the performance of social landlords in remediating 11 metre-plus buildings and the progress they are making against their plans.

Will Perry, director of strategy at the Regulator of Social Housing, said: “Ensuring tenants are safe in their homes must be the first priority for all landlords. We will continue to scrutinise the sector through inspection, engagement and monitoring to make sure it identifies risks and carries out any necessary remediation work promptly.”

The data referred to in this latest publication were reported in the Q2 2025-2026 survey, which ran from 23 September to 21 October, with data being reported as at 30 September this year.

Most relevant buildings reported (84.4% of them, in fact) have been assessed to have no outstanding or historic external wall system-related life-critical fire safety defects in any building works assessment since 14 June 2017.

Landlords reported that work had already started (or is otherwise now complete) on 21.3% (ie 397) of all affected buildings.

Life-critical fire safety defects are defined as defects, shrinkages, faults or other failings in a building that give rise to fire safety risks identified by a fire risk appraisal of external wall construction or a fire risk assessment (or equivalent) undertaken to industry standards.

The Government is committed to delivering on the Grenfell Tower Inquiry Panel’s Phase 2 report recommendations concerning fire engineers, strengthening public safety by building a highly skilled and sustainable profession exhibiting high standards of professional accountability.

The Authoritative Statement of the Fire Engineers Advisory Panel (itself established in April this year to provide advice to Government on the fire engineering profession) is a response to the Inquiry’s call for an authoritative statement of the knowledge and skills to be expected of a competent fire engineer as part of the overarching recommendation that fire engineering should become a regulated profession.

Aside from this primary aim, the Fire Engineers Advisory Panel was also asked to look at the wider context of the fire engineering profession, including education, the role and its responsibilities, behaviours, experience and skills.

The accompanying next steps statement sets out how central Government will implement both the recommendations of the Inquiry and the advice of the Fire Engineers Advisory Panel, the members of which include Professor Luke Bisby FRSE FREng (from the University of Edinburgh) and Dr Barbara Lane CEng FREng FRSE from consultancy Arup’s global fire safety practice, who served as an expert witness for the Grenfell Tower Inquiry.

Current state of affairs

The Grenfell Tower fire exposed profound and systemic failures across the building safety system, including widespread gaps in professional competence, ethical behaviours and oversight. The Inquiry showed how unclear responsibilities, inconsistent standards and weak assurance allowed unsafe practices to take hold and left residents unprotected. These shortcomings not only led to a catastrophic loss of life, but also significant societal harm and costs.

Within that landscape, the Inquiry drew attention to certain high-risk professions, fire engineering among them. The discipline “lacks a coherent educational foundation and clear, consistent requirements” for entry to the profession. There’s no single recognised pathway, and although some programmes exist and some engineers choose to become Chartered, accredited programmes, structured education and wider capacity building remain “limited and uneven”. This leads to significant variation in the qualifications and skills of those practising as fire engineers, with “insufficient emphasis” on the ethical practice fundamental to ensuring life safety.

These gaps, and the over-specialisation in siloed technical areas, are “undermining the development of a competent workforce” capable of supporting an effective regulatory system in what’s now a complex and rapidly changing built environment.

Professional practice is similarly fragmented. Fire engineering principles and the role of a fire engineer are often poorly understood or undervalued within multidisciplinary teams, leading to the marginalisation of fire engineering input. Ethical standards and expectations of professional conduct are inconsistently defined and monitored, while the variety of education and competence means that engineering principles and guidance are sometimes not applied effectively to real-life situations.

As a result, “confidence in the profession is poor” and capacity remains too low. This will not meet current or future needs, places vulnerable individuals and the wider public at risk and undermines people’s rights to safe housing.

In addressing these challenges, the establishment of fire engineering as a regulated profession has to deliver clear outcomes for the safety of people and the built environment. These outcomes include:

*a system in which buildings are consistently safe for the people who live in, use and occupy them

*a resilient and competent workforce that operates ethically and is accountable for protection of life through the quality of its work

*viable and attractive education routes leading to sustainable careers

*a profession that values its duty to protect people and so earns and maintains the trust of the public

Central to this vision is ensuring that fire engineering solutions consistently protect everyone, including the most vulnerable. “This will depend on mechanisms such as enforceable standards for entry and practice, a nationally recognised competency framework, mandatory accreditation of education pathways and robust regulatory oversight of professional and ethical conduct.”

Future regulation

The Fire Engineers Advisory Panel supports the Government’s intention to regulate both the title and function of fire engineers. While further detail will be shaped through consultation, these elements should underpin the development of statutory regulation:

*In principle, a new protected title for fire engineers will be introduced, with legal restrictions on its use

*Again in principle, statutory regulation will define the functions and activities that can only be performed by an individual who’s registered and has met specific requirements. Fire engineers will hold formal responsibility for the development and stewardship of the fire safety strategy, with clear duties defined in regulation

A competent fire engineer needs strong technical knowledge and the ability to work across disciplines. This includes an understanding of core architectural and engineering principles: fire dynamics, prevention, human behaviour, building structures, systems and operations and fire-fighting needs alongside good analytical and communication skills.

They must understand the regulatory framework across the building lifecycle in order to interpret and apply requirements proportionately. Fire engineers should clearly explain and demonstrate how their fire safety strategy meets these requirements and engage stakeholders, such as other design disciplines, contractors, Building Control/standards bodies, Fire and Rescue Services, insurers and building users.

Structured process

The Fire Engineers Advisory Panel considers that this broad foundation of knowledge and skills is comparable to other engineering disciplines wherein it’s a two-part process to acquire the skills, knowledge, experience and behaviours necessary to be formally recognised as a competent engineer. It is the Fire Engineers Advisory Panel’s view that fire engineers should operate consistently on the same principles.

This means that, long-term, the development of a competent fire engineer will be a structured process that must involve (at least both of) formally accredited education and supervised professional experience. Entry into the profession should typically begin with the completion of a relevant accredited higher education programme, which provides foundational scientific and engineering knowledge alongside specific learning in fire engineering principles and practice. The Fire Engineers Advisory Panel recognises that confidence in new entrants to the profession depends on the quality, consistency and availability of UK education programmes.

On that note, the Fire Engineers Advisory Panel recognises that university education should remain the main route into the profession. However, well-designed alternatives, such as accredited apprenticeships, may be appropriate where they deliver outcomes equivalent to a fire engineering degree.

There must also be clear pathways for existing fire engineers to demonstrate competence and for qualified professionals from other disciplines to transition into the regulated fire engineering profession.

Comment from the IFE

The Institution of Fire Engineers (IFE) has commented: “Having actively contributed to the development of the policy paper, the IFE welcomes this important publication which provides much needed clarity.”

The IFE continued: “As the global body for fire engineers, the IFE recognises the significance of this statement in shaping Best Practice and supporting the safety of communities. We will now consider the document and review its content in light of our responsibilities as a professional engineering institution.”

In conclusion, the IFE noted: “Our commitment remains to uphold the highest standards of competence and ethics within the fire engineering profession, thereby ensuring that guidance and policy continue to reflect the needs of society and the built environment.”

*Read the Authoritative Statement and the policy paper focused on next steps for reform of the fire engineering profession

The proposals follow on from the first recommendation of the Grenfell Tower Inquiry Phase 2 report, which was published in September 2024. The Inquiry Panel recommended that Government create a ‘single construction regulator’ to reduce fragmentation and complexity in the way the built environment is regulated.

The new regulator will help to ensure a well-functioning building system, which will support industry to build the homes this country needs. This will mean better outcomes for residents and building users, clarity and certainty for industry and investors and a fairer system that benefits those who prioritise safety and quality.

Samantha Dixon (Minister for Building Safety, Fire and Democracy) said: “The plans set out show how we are learning from the Grenfell Tower tragedy and what we are doing to improve the effectiveness, consistency and efficiency of the construction sector, in addition to what we’re doing to make sure people’s homes are safe and good quality.”

Dixon continued: “The case for reform is strong. One regulator across the entire construction system will be better able to review evidence, identify risks, issues and opportunities and support action with enforcement where it’s necessary.”

Further, Dixon observed: “Alongside the prospectus that we’ve published, we have also launched a consultation which seeks views on the plans from across the construction sector. This will inform final plans, while a full response to the consultation will set out more detail on regulatory reform. This is set to be published in the summer of 2026.”

Starting point for reform

Interim chief construction advisor Thouria Istephan explained: “This prospectus is the starting point for reform, which delivers on the Grenfell Tower Inquiry Panel’s call for systemic change. The creation of a single construction regulator will replace a fragmented system with one that prioritises safety, accountability and clarity, integrating the oversight of buildings, products and professions.

It’s about protecting lives, rebuilding trust and fostering a culture wherein responsibility, accountability and quality come first.”

Andy Roe, executive chair of the Building Safety Regulator, commented: “The journey towards a single construction regulator is a decisive and important step forward in strengthening building safety. Over the past few months, we’ve worked hard to speed up the application processes within the Building Safety Regulator for new high-rise residential buildings and we’re already seeing positive changes.”

Roe went on to state: “The Building Safety Regulator’s role will evolve as we move to a new body, and in longer time towards the single construction regulator, through a carefully managed transition. Throughout this process, we will continue our commitment to collaboration and delivering a regulatory system that keeps residents safe, while supporting essential construction.”

The consultation will be open until 20 March 2026. The MHCLG encourages responses from all individuals and organisations interested in the built environment.

This announcement comes as the Government publishes the next quarterly progress report on the Grenfell Tower Inquiry. As part of that, the Government has also published the Authoritative Statement of the Fire Engineers Advisory Panel on next steps for reform of the fire engineering profession​ in addition to the results of the Building Safety Regulator’s initial review of the definition of higher-risk buildings and plans for an ongoing review.

The term ‘serviced apartment’ is commonly used to refer to longer term occupancy, while ‘aparthotels’ is typically used for shorter term occupancy, although as those terms are not formally defined, this can vary significantly.

Fire safety guidance documents for blocks of flats typically expect long-term occupancy with a resulting familiarity with the building. Short-term occupancy would be closer to hotel usage, although hotel bedrooms don’t usually include the cooking facilities that would often be present in serviced apartments and aparthotels. Hotels usually provide meals in a communal location, while very often that’s not the case for serviced apartments and aparthotels.

Also, fire regulations often treat buildings that contain ‘dwellings’ somewhat differently from buildings that don’t. The definition of what counts as a ‘dwelling’ can be complex, but the duration of occupancy is typically one of the more important factors. An apartment that’s rented out by the day is unlikely to be classified as a ‘dwelling’, whereas one that’s rented for a year is more likely to meet the criteria. Duration of rental can potentially affect the regulations that apply to the building.

Regulation 5 of the Building Regulations includes various scenarios that would be classified as a ‘material change of use’, including any changes to the number of dwellings or turning the building into an hotel. As a result, converting any existing building to serviced apartments or an aparthotel would likely be classified as a ‘material change of use’, which would require full compliance with the functional requirements of the Building Regulations. The ‘non-worsening’ criteria that often applies when working on existing buildings would not apply.

Additionally, the growing trend of converting redundant city centre offices into aparthotels or flats supports urban regeneration. but raises significant fire safety concerns as conversions can be complex and, if not carried out competently, may fall short of purpose-built residential standards.

This emerging trend has raised significant concerns among fire engineers, fire risk assessors and operational Fire and Rescue Services, as well as regulatory bodies. The core issue? Are serviced apartments and aparthotels treated as blocks of flats, hotel rooms or a hybrid of the two? The answer has far-reaching implications for fire strategy, regulatory compliance and life safety.

Key issues to consider

Evacuation Strategy: ‘Stay Put’ versus Simultaneous Evacuation

Traditionally, blocks of flats are designed with a ‘Stay Put’ strategy in mind based on the assumption that each unit is a self-contained fire compartment and occupants are familiar with the escape routes and fire procedures.

The fire precautions included in blocks of flats support that approach and can vary depending on factors such as building height, but typically include fire compartmentation measures, sprinklers, smoke ventilation in corridors and separate fire alarms within each flat. The fire strategy is usually not reliant on management presence within the building to co-ordinate the early response to any fire.

However, serviced apartments and aparthotels challenge this model. When units are rented out by the day or week, occupants are transient and unfamiliar with the building (much like hotel guests). In such cases, a simultaneous evacuation strategy may be more appropriate, but this would require different design and management considerations (including enhanced detection and alarm systems, 24/7 staff presence and evacuation planning and clear signage and escape route management).

Alternatively, other evacuation strategy options could be used. One possibility that may be appropriate for some situations would be a hybrid approach whereby an initial smoke detector activation would trigger an alarm in the flat of fire origin before escalating to a full simultaneous evacuation if a heat detector activates in the flat, possibly in a key location such as in the entrance hall or near the flat entrance.

This would need careful consideration alongside the appropriate management response as well as any smoke control system in the common areas, which are typically designed for just one flat evacuating at a time. In any case, the use of sprinklers (or alternative automatic fire suppression systems) should be considered as part of the overall strategy.

Often, it would also be found that designing the building purely based on conventional hotel usage might not be appropriate because the apartments often cooking facilities, which would not normally be present in hotel bedrooms.

There would also likely be more flexibility in terms of how habitable spaces are used, while occupancy characteristics may differ from a hotel. If there are delays to the evacuation, it may be prudent to also apply the additional compartmentation and escape route protection measures typically used in apartments (possibly also with sprinklers in the apartments) to cover the more demanding scenario. Likewise, additional measures may be needed for occupants who require evacuation assistance. These additional measures would have to be decided on a case-by-case basis.

If the building includes a combination of short-term and long-term occupancy, this could create additional complexity. That would be particularly challenging if there are a combination of privately owned flats as well as aparthotel short-term rental flats within the same building. It’s unlikely to be feasible to use a combination of different evacuation strategies for the different occupancy areas, so whatever evacuation strategy is used would need to work for all areas. This may also create challenges with ownership and management responsibility.

Further, additional complexity can arise from ancillary accommodation. Many aparthotels and short-term ‘lets’ include roof terraces, gyms and shared lounge areas as part of their offer. Some fire strategies place multiple responsibilities on the security concierge, including the evacuation of these spaces in the event of a fire. This approach would typically require 24/7 staffing and a high level of training. Designers and engineers should ensure that any fire strategy relying on a managed approach is realistic in terms of the long-term financial and competence commitments required of those responsible for implementing it.

It should be emphasised that standard design guidance documents are based on standard types of buildings (referred to in Approved Document B as ‘common building situations’). Serviced apartments and aparthotels may, therefore, require bespoke fire strategies developed by a competent fire engineer who has taken into account all relevant factors.

Regulatory classification: Higher-risk building or not?

The classification of serviced apartments can also affect how they are regulated.

For example, in England, there are separate regulations that apply to Higher-Risk Buildings (HRBs). Those regulations apply to buildings that are over a certain height, but only if their occupancy contains at least two residential units, a care home or a hospital.

The term ‘residential units’ includes dwellings, student accommodation and other uses, but excludes hotels. As noted earlier, serviced apartments and aparthotels include some, but not all aspects of both dwellings and hotels. As such, at present it’s not clear whether they would be within the HRB occupancy definition, although presumably this may be clarified in future.

When designing a new building, or carrying out building works on an existing building, this distinction is critical for developers, designers, managers and regulators as it determines the level of oversight and the applicable safety standards. Building Regulations application for non-HRBs would go to the Local Authority or a Registered Building Control Approver (RBCA), whereas applications for HRBs would go to the Building Safety Regulator (BSR).

This also affects buildings in occupation as existing HRBs have to register with the BSR and ensure that there’s a Building Safety Case in place. Failure to do so could be a criminal offence. Disagreements or misunderstandings about whether a building occupancy is classified as ‘dwellings’ or an ‘hotel’ and, as a result, whether it meets the criteria for an HRB could have significant consequences.

Potentially, it would also mean that changes in usage of an existing building could alter the regulatory situation.

For example, if a tall aparthotel building that was initially only used for short-term rentals changes its approach so that two or more of the apartments are rented out on a long-term basis, to a point where they become classified as ‘dwellings’, this could mean that the building has then become an HRB, with the consequent legal implications.

Where regulations allow, it may be more prudent to treat these buildings as HRBs due to the hybrid/dual nature of the occupancy. Alternatively, seeking a legal opinion on the situation for the specific building may also help in terms of clarifying the issues.

Fire risk assessments

Under the Regulatory Reform (Fire Safety) Order 2005, dwellings are excluded from the scope of the fire risk assessment, while non-dwellings must be included in the assessment.

If serviced apartments/aparthotels are not dwellings then the fire risk assessment must legally cover the apartments themselves, not just the common areas. This has implications for the scope and depth of the fire risk assessment, the responsibilities of the ‘Responsible Person’ and enforcement and compliance.

If it’s not clear whether the serviced apartments/aparthotels are dwellings, this should be highlighted to the client. A conservative approach would be to include them within the fire risk assessment if that’s possible.

Implications for fire professionals

Fire engineers, assessors and firefighters should be alert to the following when encountering serviced apartments:

*Clarify the intended use and occupancy pattern during design and assessment stages of new buildings, changes to usage of existing buildings or for work on existing buildings. The Qualitative Design Review process is a good way of carrying this out. Ensure clients understand that any subsequent changes they make to that occupancy pattern might have significant consequences.

*Seek support from specialists if there are uncertainties relating to key issues that are outside of the fire engineer’s expertise (such as interpretations of legal definitions).

*Challenge assumptions about evacuation strategy. ‘Stay Put’ may not be suitable.

*Fire strategies relying on managed evacuation must reflect realistic staffing, training and financial commitments.

*Ensure fire risk assessments are legally compliant, particularly if the units are not classified as dwellings.

*Engage with developers and Building Control bodies early to determine the correct regulatory pathway.

*Basing designs purely on guidance for blocks of flats or hotel usage may not be appropriate. These types of buildings demand bespoke strategies developed by competent fire engineers.

Call to Action

Given the growing prevalence of serviced apartments and the confusion surrounding their classification, the Institution of Fire Engineers (IFE) and the Fire Industry Association (FIA) have published this short introductory guide to help practitioners navigate the regulatory landscape and ensure that fire safety strategies are appropriate, legal and effective. The IFE and the FIA would encourage further work to be undertaken on this complex issue.

Paul Trew is Technical Director at the IFE. Ian Bailey IEng MIFireE is Fire Engineer for CROSS-UK and Technical Advisor with the IFE. David Quinn is Director and Head of Fire Engineering for the UK and Ireland at BB7 Consulting (and Technical Panel Chair and member of the IFERG and IRP Panels). Jon Pagan is Head of Technical Operations at Kiwa IFC Group and Co-Chair of the IFE/FIA Façades Special Interest Group. Ian Moore is CEO of the FIA (www.ife.org.uk and www.fia.uk.com)