How do UK fire safety design regulations compare to those of countries in the EU?

Posted by Conor Logan on 24/03/21 10:00

SOUTHBANK-TOWERThe Grenfell review from Dame Judith Hackitt concluded that the current legislation regarding fire safety equipment in the UK is not fit for purpose and that it needs to improve. Learning the best that we can from other countries (such as those in the European Union) while avoiding their shortcomings would be a good start.

But while well-considered fire safety regulation is essential, it is equally important for all those involved in the design and construction of buildings and construction products to have an understanding of what fire can do to a building and how damage and danger can be minimised.

Fire safety design in the EU

When we look at our European neighbours, we can see that while not all of them follow the same rules, there are some different approaches to design than the UK, particularly in relation to fire safety and smoke control. In the UK, we currently follow a performance-based code where the regulation only mandates five basic requirements of means of warning and escape, internal fire spread – linings and structure, external fire spread and access and facilities for the fire service.

The method used to meet these requirements is down to the designer and can be derived from a number of sources – government guidance (each of the devolved nations has its own version with slightly different approaches), a risk-based approach from British Standards or a fire engineered solution using specialist knowledge and resources.

Whereas, in Germany, for example has entirely prescriptive regulations and standards which tell building designers what they should and should not do. The national model building code (Musterbauordnung) sets out what standards designers should meet. Each of the federal states has its own detailed rules, but in fact these vary only slightly. The benefit is that life safety systems should not be traded off under the pretext of ‘value engineering’. The trend of a ‘race to the bottom’ as referred to by Hackitt, in terms of providing the minimum protection for the lowest cost needs to be halted. Prescriptive requirements are more likely to prevent this as compliance is the only sure way of demonstrating the standard is met.

Sweden, for example, also allows performance-based design, but has strict rules about considering the possibility of fires in adjacent buildings. Italy has an older approach of prescription and a newer approach that allows for a more 'creative' design, similar to the UK's. This newer approach is not, however, proving popular because it passes responsibility from the authorities to the design team. Designers in Italy, it seems, prefer to tick boxes than think through the design process.

It is true that performance design, to be done well, requires a detailed understanding of how a building will behave in a fire. That is why an entire specialism of fire engineering has built up. Sometimes, however, the motivations of the fire engineer can be questionable – whose interests do they serve? Their client or the end user? Are they looking to justify the minimum cost for their client or the minimum level of safety that they can comfortably justify and are the two intrinsically linked?

The Dutch Building Decree also uses a performance-based approach which takes a particular approach to the limitation of the spread of smoke. It is also the only documentation in Europe that specifically sets out requirements to limit the development of smoke.

Most of the countries with different approaches have also experienced catastrophic fires and these have often shaped their legislation and regulation. In most countries, fire design has to be considered at the start of the process, and in others it comes much later. It is unlikely that any of them get it entirely right. There has to be a balance between the essential need to ensure safety and being so prescriptive that design becomes nearly impossible. Our experience has been that it is easier to incorporate the right protection earlier so that it is considered in the design process.

Fire safety design in the UK

As mentioned earlier, in the UK, we currently have a performance-based code. This describes how a building should behave in terms of fire and it is then up to the designers to show that the measures that they have put in place will allow the building to achieve that performance.

The idea is that this allows designers to be more creative and still have buildings that perform well. But interpretation can be difficult. Following a fire at Lakanal House in 2009, which killed six people, the coroner at the inquest called Part B of the Building Regulations, which set out the performance standard, ‘a most difficult document to use’.

To complicate matters further, there is not currently one standard code that the four UK nations adhere to. Fire safety designers in England work to Approved Document B, Northern Ireland, Wales and Scotland follow other guidance. An example of these differences is that in England, Wales and Scotland, combustible cladding is banned for residential buildings over 18m tall. With regards to sprinklers - in England, they are required in buildings above 11m, while in Scotland, the regulations require sprinklers in all multi-occupancy residential buildings, regardless of height, and in Wales any residential building, regardless of multi-occupancy, needs to have residential sprinklers. Meanwhile, in Northern Ireland, a combustible cladding ban has not yet been introduced, nor has the mandated use of sprinklers in residential blocks.

With all these seemingly small (but very important) differences between different areas in the UK and what could be argued to be an unhealthy focus on minimising cost, have we gone too far towards a performance standard, and away from prescription, when it comes to fire safety and construction products regulation?

That question is now starting to be addressed with the introduction of the Draft Building Safety Bill, and similar legislation in Wales and Scotland, and the Fire Safety Bill, which will bring forward necessary reforms to the service and maintenance of high-risk buildings, with a clear focus on improving both building and fire safety – it can only be a matter of time before the NI Executive puts similar measures in place. Each Government’s objective is for the long-lasting reform of the building safety system so that people will be, and will feel, safer in their homes. And, crucially, they can trust in the competency of those who are responsible for the service and maintenance of their building.

Read more about the bill in my full blog about it here.

Colt is the UK’s most experienced supplier and servicer of smoke control systems and fire curtains. If you want an intelligent, considered approach to safety, contact Colt.


Conor LoganConor Logan CEng FIMechE FCIBSE is Technical Director of Colt UK. Conor designs innovative smoke control and HVAC systems, represents Colt on many UK and EU standards committees and was Chairman of the Smoke Control Association for over 9 years.

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Topics: Smoke Control, smoke control maintenance, Fire Safety