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Amendments to Approved Document B on Fire Safety

Statutory guidance in Approved Document B sets out how external walls can meet the Building Regulations requirement for resisting fire spread. The principle of carrying out an assessment in lieu of test (also known as desktop study) is a well established part of the system for classifying the fire performance of construction products and systems. This consultation looked at restricting or banning the use of desktop studies as a way of assessing the fire performance of external cladding systems.

Objectives of the consultation

Dame Judith Hackitt’s Interim Report on the Independent Review of Building Regulations and Fire Safety indicated concerns with the current approach to the use of assessments in lieu of tests for cladding systems.
 
One of the recommendations was that: “The government should significantly restrict the use of desktop studies to approve changes to cladding and other systems to ensure that they are only used where appropriate and with sufficient, relevant test evidence. Those undertaking desktop studies must be able to demonstrate suitable competence. The industry should ensure that their use of desktop studies is responsible and in line with this aim.”

This consultation set out proposed amendments to Approved Document B (statutory guidance on fire safety) to ensure that assessments are carried out correctly, in line with Dame Judith’s recommendation. The proposed changes included improving the transparency of assessments, enabling proper scrutiny of results and ensuring that the studies can only be carried out by properly accredited bodies that have the relevant expertise.

The consultation also sought views on whether the Government should go further and prohibit the use of assessments in lieu of tests either for all fire test classifications or for fire test classifications relating to cladding systems.
 
The Government response to this consultation will also take into account findings and recommendations made by Dame Judith Hackitt’s final report on the Building Regulations and Fire Safety system, published .

The consultation closed on 25 May 2018.

Supporting papers

To download the consultation document, please follow the link below.

CIBSE response

CIBSE agrees with Dame Judith’s recommendation that the Government should significantly restrict the use of desktop studies to approve changes to cladding. The use of desktop studies or assessments in lieu of test is unique to the UK, with virtually no parallel elsewhere in the world. Most other jurisdictions require test data and do not recognise such assessments.

CIBSE does not agree with the proposed approach of amending an Appendix to Approved Document B. Amending the text  of Approved Document is only amending guidance. If the intention is to restrict the use of assessment’s in lieu of test, then this can only be done in an enforceable manner if the regulations are amended. A change to the regulations, rather than the guidance, will contribute to achieving the intended outcome. However, as Dame Judith herself makes very clear, there are no single solutions to address the systemic failings in the overall system of regulation and control of buildings. This is an important element of delivering a solution.

Dame Judith calls for buildings to be considered as systems, and as well as considering the test requirements for cladding and external insulation other aspects of the life safety systems of the building such as active and passive fire protection also need to be considered.

To read the full CIBSE response, please follow the link below.