DLUHC: Proposed changes and effects on fire doors and stairs

In this blog, BWF Technical Director Kevin Underwood offers an overview of The Department for Levelling Up, Housing and Communities (DLUHC) current consultation, and how the proposed changes to Approved Document B will affect fire doors and stairs.

Currently DLUHC is consulting on changes to the building regulations for England that will affect fire doors and stairs.

Full details on the consultation and how to respond can be found on the Government’s website www.gov.uk

This consultation opened on 23 December 2022 and closes on 17 March 2023.  

The information that follows shows proposals made by DLUHC for changes to the guidance within Approved Document B. These are not yet set and may change depending on the responses that are received during the consultation.

Removal of national classifications 

Much of the guidance in Approved Document B is given in terms of performance classifications in relation to British Standards (BS) or British versions of European Standards (BS EN).

During the Grenfell Tower Inquiry the use of the national classification standards for reaction to fire and fire resistance in Approved Document B came under scrutiny, and potential flaws in their use were identified. The criticism focused on the BS 476 series, known as the national classes.

In response, DLUHC removed reference to the national classifications from the main body of Approved Document B in 2019, and they are now only included within the annexes. In the next update to Approved Document B DLUHC plans to remove the remaining references to all aspects of the BS 476 series. This will mean, for example, that the FD30 and FD30S classifications for fire doors, which are based on BS 476 testing, will be withdrawn.

Given the time that has elapsed since the introduction of the European Classifications in the early 2000s but recognising there are ongoing capacity issues for product testing, and that the change will cause disruption within some industries, DLUHC is proposing a 12-month transition period upon implementing the changes.

Staircases in residential buildings 

Currently, for blocks of flats, Approved Document B does not set a threshold above which more than one staircase must be considered.

DLUHC is concerned that some tall residential buildings are being designed with a single staircase without due consideration by the designers on the level of safety provided and the necessary resilience. DLUHC is therefore consulting on options to introduce clear guidance in Approved Document B recommending the provision of a second staircase in new residential buildings of more than 30 metres in height. 30 metres is an accepted threshold for increased safety measures such as increased fire resistance provisions and marks a recognised trigger representing an increase in the level of risks in buildings overall.

Recognising that many schemes are in development, and this proposal would be a significant change, DLUHC is proposing a very short transition period. The transition period will allow time for schemes to be completed but should not allow the opportunity for developments to get off the ground ahead of the new requirements coming into effect. DLUHC is encouraging all developers to prepare for this change now.

Combustibility of insulation materials used on external walls

Approved Document B contains provisions in paragraphs 10.6 and 10.7 that restrict the combustibility of insulation materials used on external walls which were criticised during the Grenfell Tower Inquiry as lacking clarity. DLUHC is considering a revision of these paragraphs and are seeking views on how best to improve the guidance and ensure it is as clear as possible.

DLUHC’s intention is to launch a call for evidence through its consultation to determine which materials should be captured in these provisions and how to improve the clarity of wording describing them.

Sprinkler provision in new care homes 

There is currently no blanket recommendation for sprinklers in all care homes within Approved Document B, however, the benefits of sprinklers are recognised in the guidance. Several allowances are made in Approved Document B for care homes where sprinklers are provided, including fire doors not needing self-closing devices.

Care homes rely on various measures to resist fire spread within the building which aim to limit the number of people who need to be evacuated initially and to protect residents elsewhere in the building. These measures underpin the progressive horizontal evacuation strategy adopted in care homes. While the current provisions in Approved Document B are effective overall, DLUHC recognises the importance of controlling fire spread in areas where people are likely to rely on the assistance of others in order to evacuate.

DLUHC is minded to proceed with a change to Approved Document B which recommends that sprinklers that conform to BS 9251:2021 are used in all care homes, irrespective of height, or, as an alternative approach, to consider 10 beds, which represents a perceived change in the level of risk in the building, as a threshold value triggering the need for sprinklers.

DLUHC is proposing a transitional period of 6 months before the changes would apply.