Open consultation

Review of Approved Document B: Fire safety

Updated 15 April 2026

Applies to England

About the consultation

We are consulting on proposed changes to Approved Document B: Fire safety (ADB). These would clarify and update the guidance, revise the rules on combustible materials in external walls and attachments, and introduce a new requirement for evacuation lifts.

Bodies responsible for the consultation

The Building Safety Regulator (BSR), Health and Safety Executive (HSE) and Ministry of Housing, Communities and Local Government (MHCLG).

Duration

The consultation runs for 14 weeks from 25 March 2026 to 1 July 2026.

Enquiries

For any enquiries about the consultation please contact ADBconsultation@hse.gov.uk.

How to respond

We encourage you to respond by completing an online survey, Review of Approved Document B: Fire Safety (consultations.hse.gov.uk).

Alternatively, you can email your response to the questions in this consultation to ADBconsultation@hse.gov.uk.

If you are responding in writing, please make it clear which questions you are responding to.

Written responses should be sent to:

Building Safety Regulator
Health and Safety Executive
4th Floor
10 South Colonnade
London E14 5EA.

When you reply, it would be useful if you confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:

• your name
• your postcode (if applicable)
• the name of organisation (if applicable)
• an address (including postcode)
• an email address
• a contact telephone number

Please also indicate whether you are responding to this consultation as a:

• builder or developer
• designer, engineer or surveyor
• local authority
• building control approved inspector
• architect
• manufacturer
• insurer or lender
• construction professional
• property manager, housing association or landlord
• landlord representative organisation
• building occupier or resident
• tenant representative organisation
• other interested party (please specify)

Consultation question i

What is your name?

Consultation question ii

What is your email address?

Consultation question iii

Are you responding as an individual or on behalf of an organisation?

If you answer “on behalf of an organisation” please provide us with the name of your organisation.

1. Introduction

1: Building regulations set technical requirements covering a wide range of health, safety, access, security and sustainability issues.

2: The building regulations requirements are intended to protect people’s safety, health and welfare in and around buildings. The regulations are supported by statutory guidance in ‘approved documents’ which provide practical guidance on ways to comply with the requirements in the regulations for many common building situations only.

3: ADB provides guidance for Part B of the buildings regulations, relating to fire safety.

4: Section 14 of the Building Act 1984 requires consultation for proposed substantive changes to the building regulations. It has been our practice to carry out a public consultation on proposed changes to the Approved Documents, as the implications of changes can be complex and BSR believes that public consultation adds significant value.

Grenfell Tower Inquiry Phase 2 report recommendations

5: In September 2024 the Grenfell Tower Inquiry published the Grenfell Tower Inquiry Phase 2 Report (https://webarchive.nationalarchives.gov.uk/) setting out 58 recommendations for government to consider in its response to the Grenfell Tower fire. In February 2025 the government accepted all the Inquiry’s findings and committed to providing updates on progress against the recommendations on a quarterly basis.

6: MHCLG has asked BSR to support the government’s response to the Grenfell Tower Inquiry Phase 2 report to recommendations 5, 7, 8, 11 and 12 relating to issues that are to be considered as part of the review of ADB.

7: Recommendation 5 of the phase 2 report made clear that “the statutory guidance generally, and ADB in particular, be reviewed accordingly and a revised version published as soon as possible.”

8: This consultation will deliver on key parts of recommendation 5 (with the wider review of Approved Documents still ongoing^{[footnote 1]}), and enable a full response to recommendation 12.

Continuous review of Approved Document B

9: Ahead of the full government response to the Phase 2 report, the government announced in December 2024 that BSR has been instructed to keep the guidance within ADB under continuous review. This is in line with BSR’s statutory duty under section 5 of the Building Safety Act 2022 to keep the safety and standards of all buildings under review.

10: The continuous review programme brings together 3 core strands.

a: Technical review. Following a 2018 call for evidence, government commissioned 10 research projects covering key fire safety themes. Seven reports from this phase of research have been published in December 2025 to support this consultation, in addition to 2 reports that were published in support of previous consultations.

b: Horizon scanning. BSR monitors trends to anticipate future risks and inform development of guidance. This includes the long-standing investigation of real fires programme. Running since the 1980s, this strand of research investigates fire incidents to identify patterns and inform options for changes to building regulations and future guidance. Five new research reports have been published alongside the consultation and yearly summaries will be published going forward, with the first 2 published in August 2025.

c: Sector engagement. Guidance is shaped through regular dialogue with the Building Advisory Committee and its Part B Fire Safety Working Group. Each research project was and will continue to be supported by a technical steering group of industry and academic experts.

11: The continuous review of ADB forms an important objective of BSR. This review ensures that we continuously identify areas of the guidance which either already need strengthening or will need to be strengthened in the future. This approach ensures that areas of the guidance which have not been reviewed yet, will be. This allows us to identify at the earliest opportunities how new materials and methods of construction challenge the guidance and adapt it to enable safe innovation in the construction sector.

12: Our objective for the continuous review is to bring forward changes to the guidance at planned frequent intervals. This gives the construction industry time to engage with the review and organise their work going forward accordingly.

13: Alongside this consultation, BSR has published further information on the scope of the continuous review of Approved Document B.

Overview of consultation

14: The government made a commitment in December 2024 for BSR to keep ADB under continuous review. Building on this, announced through the government’s response to the Grenfell Tower Inquiry Phase 2 report in February 2025, and reiterated through the government’s Grenfell Tower Inquiry annual report in February 2026, BSR has now launched the consultation on further changes in March 2026.

15: The government response recognises that the guidance in ADB has been updated several times since 2017.

16: Delivering on this commitment, BSR is now consulting on proposed options for:

• small but important clarifications and technical changes to the guidance within ADB
• consolidated guidance for designing building work on existing buildings
• the introduction of a threshold whereby the guidance within Approved Document B should not be applied when combustible elements of structure are used
• revised and updated guidance on external wall systems and balconies, and review the scope of the ban on combustible materials in and on external walls
• new provisions for evacuation lifts in residential buildings above 18 metres (m), and clarifying the related guidance for non-residential buildings
• updated terminology on ‘sheltered housing’, introducing the new term ‘specialised housing’ in its place and increased provisions for detection and alarm coverage in these buildings types
• updated guidance on roofs including new provisions for the incorporation of photovoltaic (PV) panels
• increase in the fire resistance rating of open-sided car parks

17: This consultation covers areas where sufficient evidence has been found to support the inclusion of changes in the technical review of ADB. To further support this consultation, the research reports have been published in December 2025.

18: This consultation provides the opportunity to review and comment on the updated guidance text. This allows direct feedback on the wording of the changes to ensure they are clear and unambiguous. The consultation makes clear within each section where the guidance can be found, whether within the consultation document itself, through the online portal or via external links to documents.

19: It should be noted that through the changes highlighted there is no suggestion that existing and upcoming buildings are inherently unsafe, as long as they have been built in accordance with the relevant standards at the time, are well-maintained, and properly managed.

Combined impact of changes

20: BSR takes the impact of new standards on the construction industry very seriously. We have carried out detailed assessments of the proposals in this consultation to ensure that they are proportionate and any impact from changes to the guidance is mitigated where possible.

21: The proposed preferred options outlined in the consultation below will have a cumulative cost spread across all building types of £199 million over a 10-year period, with an estimated net annual cost to business (ENACB) of £29 million per year. Of this, the cost of familiarisation is anticipated to be £12.6 million over 10 years with an ENACB of £1.3 million per year. The specific impacts of proposed changes are outlined in each section of the consultation.

22: Across all the changes, there are a range of benefits that will be achieved across the built environment and for residents. There are inherent challenges of quantifying benefits from improvements to building safety and at this stage the benefits have not been costed.

23: Based on our assessment, the benefits of clarifying the guidance and greater regulatory alignment with industry and planning guidance include:

• easier to design schemes leading to reductions in design time
• reducing the number of schemes underproviding fire protection measures to improve the consistency in fire safety provisions across buildings
• improved clarity for non-design professionals (such as the fire and rescue service, building control bodies and residents) reducing the risk of misinterpretation, improved operational clarity and potential for faster approvals
• reducing the risk of future remediation due to better initial compliance and limiting post-occupancy corrections

24: Further benefits can be derived by the increased fire performance specifications which include:

• improved fire safety and the reduction in fire spread, damage and casualties in the event of a fire
• standardised and improved features improve fire service operations and pre-planning allowing for a faster and safe emergency response
• clarity for insurers and financiers reducing the perceived fire risk leading to improvements in underwriting and financing conditions

25: Further generalised benefits include the wellbeing benefit of residents who feel safer in their homes.

Transition periods

26: Following public consultation, we will finalise the guidance and publish a full consultation response once all of the inputs have been adequately considered. All the proposals outlined within this consultation have a target implementation date of 2nd September 2029. This implementation date aligns with the existing 2029 amendment booklet to ADB and enables a full new version of ADB to come into effect from that date.

27: By aligning the transition dates, we simplify when changes take place and make the guidance within ADB clearer. The alignment also provides an extended transition period allowing industry more time to adapt to the new guidance and minimise the impact on buildings currently within the planning process.

28: Through the impact analysis supporting this consultation, a 2-year transition has been assumed. There is the potential for the actual transition period to be longer.

Consultation question 1

Do you agree that the changes within this consultation should be aligned with existing changes to Approved Document B coming into effect on 2nd September 2029?

Consultation question 1a

If you disagree, please provide your evidence on an alternative enforcement date.

Aim of the consultation

29: The consultation on ADB is proposed to cover the specific areas highlighted through the consultation document only.

30: The consultation is to collect evidence and views on the areas of the guidance being updated.

31: We are reviewing ADB as part of BSR’s commitment to continuous improvement in the guidance. It may be that feedback from this consultation cannot be included within the next revision of ADB due to time and resource constraints but may be included in a future update to the guidance.

2. Grenfell Tower Inquiry recommendations

32: Alongside recommendation 5 of the Grenfell Tower Inquiry Phase 2 report, BSR has been asked to support the response to recommendations 7, 8, 11 and 12 solely related to guidance within ADB. While this consultation responds to recommendation 5 and fully considers recommendation 12, recommendations 8 and 11 will continue to be considered as part of the continuous review of ADB. Changes to the guidance based on these recommendations will follow in due course.

33: BSR is also supporting MHCLG on a number of the other recommendations from the phase 2 report which are not covered by this consultation.

34: Recommendation 12 of the Grenfell Tower Inquiry Phase 2 report asked government to consider how the guidance in ADB deals with interpreting results and the need for sufficient test data. “BS 9414 should be approached with caution and we recommend that the government make it clear that it should not be used as a substitute for an assessment by a suitably qualified fire engineer.”

35: Through the 2019 clarification to ADB, the text in Appendix A, now Appendix B, was updated to make clearer that:

“B2: Any test evidence used to demonstrate the fire performance classification of a product or system should be carefully checked to ensure that it is applicable to the intended use. Small differences in detail, such as fixing method, joints, dimensions, the introduction of insulation materials and air gaps (ventilated or not), might significantly affect the performance and should be tested or assessed in accordance with paragraph B1.”

“B3: Assessments should not be regarded as a way to avoid a test where one is necessary. Assessments should only be carried out where sufficient relevant test evidence is available. Relevant test evidence is unlikely to be provided by test standards which have different classification criteria.”

36: While BS 9414 is one approach for extending the results of BS 8414 tests, it may not be the only guidance available. BSR believes that keeping the guidance as outlined above generic to any standards will ensure that there is no ambiguity about how to approach interpreting results.

Consultation question 2

Do you agree that the existing text within Approved Document B provides sufficient clarity on the need for sufficient test data when seeking to interpret results, yes or no?

Consultation question 2a

If you disagree, what changes to the text can be made to improve the clarity?

3. General updates and clarifications

37: BSR is committed to keeping the statutory guidance for fire safety under continuous review. Through our programme of research, our ongoing engagement with industry, and correspondence received by BSR and MHCLG, we are able to identify areas which require:

• correction due to typographical errors
• revisions to the text to ensure clarity of the guidance intent
• improvements in keeping up to date with modern materials, construction practices and changing demographics

38: Through the consultation, we are seeking to implement small but important changes to improve the guidance and provide industry with the clarity it needs to support the government’s ambition to build 1.5 million homes this Parliament.

39: In addition, BSR seeks to incorporate aspects from several of Approved Document B’s frequently asked questions (FAQs) into the guidance. This will ensure that the guidance document is clear on the intent of the provisions and scope of the guidance.

40: The general changes to the guidance include updates to:

• structure – replacing the current listing of structural elements with the term ‘elements of structure’. This ensures items that are not typical are not excluded from the overall fire performance of a building and improves clarity of the document

• cavities – clarify intention of recommendations and remove any deemed-to-satisfy provisions as part of the wider strategy of making the guidance performance-based and not naming specific materials or products. The wider clarifications are to improve reading of an area where there is some confusion with industry

• roofs – changes to the guidance on roof coverings and recommendations on when a roof should be considered an element of structure, with the aim to reflect modern roofing developments. The proposed changes amend what were considered confusing diagrams and clarifies some paragraphs based on guidance within other parts of ADB

• balconies – inclusion of fire resistance recommendations and provision of clearer guidance for external balcony approach to flats. This removes the only reference to BS 9991 in ADB, and lowers risk of sudden balcony collapse and associated harm

• smoke ventilation – improving readability of guidance and ensuring language aligns to other parts of ADB

Consultation question 3

Do you have any comments on the small but important clarifications and minor technical changes draft guidance text?

Consultation stage impact assessment

41: All of the changes considered as part of the general updates and clarifications have been assessed to have negligible impact on industry practices. These changes are to assist clarity.

42: The economic cost of these changes is limited to the familiarisation cost to designers and engineers in the time they will take to review and understand the updated text.

Consultation question 4

Do you have any further benefits that should be considered?

4. Clarification of applicability of Approved Document B for existing buildings

43: Section 0 of ADB provides insight on when the guidance within the document should apply. The introduction of the Building Safety Act 2022, and the wider updates to the Regulatory Reform (Fire Safety) Order 2005 through the Fire Safety Act 2021 brought the need for some additional clarifications to be made to this section of the guidance.

44: These changes will build upon and consolidate clarifications set out through circular letters and ADB FAQs 11 and 26. The new text aims to provide improved clarity and allow industry to meet reasonable expectations of fire safety, aligning with the fire strategy, fire safety management plan, and fire risk assessment, in existing buildings when new building work is carried out. This will further meet the need to make the building application process uniform and streamlined across the board.

The proposed new text:

“Existing buildings

“Building work in an existing building must comply with the relevant requirements of the Building Regulations.

“Regulation 4(3) of the Building Regulations states the following:  

“(3) Building work shall be carried out so that, after it has been completed — (a) any building which is extended or to which a material alteration is made; or (b) any building in, or in connection with, which a controlled service or fitting is provided, extended or materially altered; or (c) any controlled service or fitting, complies with the applicable requirements of Schedule 1 or, where it did not comply with any such requirement, is no more unsatisfactory in relation to that requirement than before the work was carried out.  

“When meeting these requirements, consideration should be given to the impact the building work has on the level of safety of the existing part of a building. The modified parts of the premises or parts of the existing building may need to be upgraded to ensure that the level of safety of the existing part is not lowered. What may appear to be a minor modification can introduce new risks and significantly affect the level of safety in the building. Dutyholders should therefore assess the broader implications of the work, including its interaction with existing fire safety measures.    

“Dutyholders should consider the content of the fire risk assessment required by the Regulatory Reform (Fire Safety) Order 2005 when setting the scope of the building works. In some buildings, the fire risk assessment may highlight levels of safety which although met standards at the time of construction are now lower than contemporary standards. When planning building works dutyholders should consider if improvements to the current fire safety measures of the building are proportionate under the Regulatory Reform (Fire Safety) Order 2005. This can support the alignment of the fire strategy, fire safety management plan, and fire risk assessment into a coherent and proportionate set of measures. Regardless of the minimum requirements of the Building Regulations, there is merit in providing additional fire protection throughout the building where reasonably practicable.”

Consultation question 5

Do you agree that the proposed text provided improves clarity and encourages alignment with the fire strategy, fire safety management plan, and fire risk assessment, yes or no?

Consultation question 6

Do you have views on the content, structure, and style of the proposed text?

Consultation stage impact assessment

45: BSR sees this change as a clarification of existing expectations and our analysis has showed that there will not be a cost to industry by implementing this clarification.

46: Expected benefits of this change may be reduced design time, improved compliance, and improved safety levels in existing buildings which undergo building work.

Consultation question 7

Do you have views on what impact this text may have on industry?

Consultation question 8

Do you have views on potential benefits of the change?

5. Combustible elements of structure: Introducing a height threshold for use of Approved Document B

47: Timber is a traditional building material that has been used successfully for centuries to provide low-rise housing in England. Recent developments in mass timber solutions have provided structural timber configurations that could support the use of timber in increasingly tall buildings.

48: High-rise buildings have traditionally been built out of systems that do not contribute as fuel, such as masonry, concrete and steel. In case of fire, these traditional systems achieve a high fire resistance rating which provides for post-fire performance of elements of structure. The emergence of mass timber construction systems has challenged the fundamental assumptions underpinning the guidance.

49: While ADB and its guidance on fire resistance ratings is seen as suitable to support the use of timber structures in low-rise buildings, BSR is clear that some parts of the guidance cannot be used for high-rise timber buildings. Government published Approved Document B FAQ 23 in 2022 making clear that tall, large or complex buildings with combustible elements of structure are out of scope of ADB.

50: To clarify what BSR considers as “tall, large or complex” when combustible elements of structure are utilised, we are seeking to introduce a clear threshold within the guidance. The threshold will make clear the height above which buildings using combustible structural elements (including timber) cannot solely apply the guidance within ADB to demonstrate compliance. Where combustible structural elements are used, an alternative approach is expected.

51: A threshold of 11 metres is proposed in consideration with the guidance on consequence classes in Approved Document A and published industry guidance and standards. This strengthens the connection between ADB (Fire safety) and Approved Document A (Structure) by aligning fire safety guidance with the principles of preventing disproportionate collapse. This alignment enhances the coherence between the two documents and reinforces their shared intent.

52: While the change to the guidance incorporates a FAQ which outlines the current intent of ADB, we recognise that this clarification may have an impact on the use of combustible structural elements above the threshold.

53: BSR seeks to be clear that we continue to support the use of timber in both residential and non-residential low-rise buildings. Our position aligns with the Timber in construction roadmap 2025 that seeks to “increase the safe use of timber in construction in England, to help reduce embodied carbon in the built environment and drive investment into tree planting, forest management and domestic supply chains, creating new green jobs and industries”.

54: The lower risk profile of buildings below the threshold set out above, means that timber can continue to be used safely and where the environmental benefits are more significant, with sufficient consideration of fire safety, structural safety and durability considerations. Timber in low-rise construction is where the associated environmental benefits are more significant. The new threshold still allows for timber to be used above 11m by ensuring a full fire engineered approach is taken.

55: In line with priority theme 5 of the Timber in Construction Roadmap, aimed at  “addressing fire safety and durability concerns to safely expand the use of engineered mass timber.” We are committed to working with industry, academia, and the wider sector to further investigate outstanding fire safety, durability, and competence questions.

56: To support ongoing development of research into the deployment of timber structures at height, BSR published research conducted as part of the technical review of ADB that considered the fire safety risks associated with fully encapsulated mass timber, Fire safety: Structural fire resistance .

Consultation question 9

Do you agree that Approved Document B should include a threshold above which the guidance should not be used when combustible elements of structure are used, yes or no?

Consultation question 10

Do you agree that the 11m threshold is appropriate, yes or no?

Consultation question 10a

If you do not agree with the question 10 statement, at what height do you believe the threshold should be set?

Consultation question 11

Do you have any comments on the draft guidance text? 

Consultation stage impact assessment

57: BSR plans to incorporate the FAQ into the guidance within ADB and state a clear threshold of 11m for both residential and non-residential buildings where ADB is not suitable if the building uses combustible structural elements.

58: The options considered were:

a) Option 1 (preferred): Introduce a threshold of 11m above which Approved Document B cannot be used when combustible structural elements are used

b) Option 2: Introduce a threshold of 11m for residential buildings and 18m for non-residential buildings above which Approved Document B cannot be used when combustible elements are used

59: Our preferred approach has an estimated cost of £0.74 million over 10 years, with an estimated net annual cost to business of £0.08 million. The costs are associated with the additional design time necessary to develop a fire engineered solution over and above an ADB-based solution. Given the low number of buildings above 18m designed using combustible elements of structure that aren’t already taking a fire engineered approach, we are confident in the expected impact.

60: Splitting the threshold to 11m for residential buildings and 18m for non-residential buildings would have a reduced cost of £0.6 million over 10 years with an estimated ENACB of £0.07 million. In our view, the complexities in fire safety design in buildings above 11m extend beyond the guidance provided in ADB to be considered sufficient on its own.

61: We anticipate that with this increased clarity, any existing hesitation within the industry regarding the use of combustible structural elements will diminish over time, particularly in light of ongoing research efforts and the sector’s commitment to advancing sustainable construction practices.

6. External walls, balconies, and ban on combustible materials in and on external walls

62: The Grenfell Tower Inquiry Phase 2 report made clear that the guidance for resisting fire spread over external walls in section 10 of Volume 1 and section 12 of Volume 2 of ADB should be reviewed as a priority.

63: Since 2017, sections of ADB providing external wall guidance have undergone several technical changes. These include:

• introducing the ban of combustible materials in and on external walls above 18m in relevant buildings in 2018
• clarification of ADB in 2019
• addition of new section on balconies
• introducing new guidance for residential buildings between 11m and 18m in height

64: The technical review of ADB included a research workstream on the classification of external wall systems. Although this research is not yet finished, the work undertaken so far has informed this new draft guidance. The objective of the redraft is to provide clear, and comprehensive guidance on external fire spread and go further in some places.

65: Through the 2022 Sprinklers in care homes, removal of national classes, and staircases in residential buildings consultation, we undertook a call for evidence on paragraphs 10.6, 10.7 of ADB 2019 edition. We have also proposed changes expanding the current guidance to respond to the evidence provided through the call for evidence.

66: The new guidance established recommendations for all buildings of any height. We have also extended the guidance to the whole external wall system to remove any doubt about its scope and application. This includes advice on the performance of the backing layer, insulation, and the external product (to also cover composite products). Any deemed-to-satisfy provisions are proposed to be removed, and their remit will be replaced with performance classifications.

67: Through updating this section of the guidance, we aim to clarify:

• that fire spread over roofs and external fire spread via balconies comes under requirement B4 in the intent section
• the section’s height thresholds and measurements align to those with the rest of the document and Appendix D, and clarify the provisions for single storey buildings
• the separation of envelopment hazards (spread over the wall of the building) and the exposure hazards (building to building fire spread)

68: The ban on combustible materials in and on external walls and specified attachments is prohibiting the use of laminated glass products as balustrades. The sector, through the 2018 call for evidence, raised this as a topic to be investigated and further explored.

69: Research underpinning the continuous review of ADB investigated the matter in detail, which involved extensive laboratory and large-scale experiments. Based on the findings of our research on balconies, spandrels and laminated glass, we are amending the current guidance on balconies in all buildings and consulting on further changes to the building regulations. This will involve proposing recommendations in the guidance and an exemption to the ban correspondingly to allow the use of laminated glass balustrades of certain dimensions and characteristics.

70: The changes to the guidance better support the balance of proportionate provisions and will clarify the relevant performance standards for components of the external walls and balconies and where the provisions apply.

Consultation question 12

Do you agree that section 10 (Approved Document B volume 1) and section 12 (Approved Document B volume 2) would benefit from being updated and clarified, yes or no?

Consultation question 13

Do you agree that the updated guidance provides greater clarity, yes or no?

Consultation question 13a

If you disagree, or have further comments on the clarity of the text, please provide any views and evidence on how the guidance could be further clarified or improved?

71: Regulation 2(6) provides the definitions for the relevant terms for the ban of combustibles in or on external walls and specified attachments. Regulation 7(3) provides a list of exemptions to the ban. The following text is proposed, following the findings of the research, as a definition for laminated glass products to be included in regulation 2(6) so that they become exempt under regulation 7(3):

“Laminated glass products are defined (in regulation 2(6)(X)) as any panel or sheet, having a total thickness of more than 17.5 millimetres (mm) but no more than 26mm which is composed of 2 or more layers of glass, and one or more layers of interlayer material which is a substantial layer made of a material having a gross calorific value of no more than 41 megajoules per kilogram (MJ per kg) when tested in accordance with BS EN ISO 1716 and a thickness less than 1.6mm. A substantial layer is defined as a layer which is at least 1mm thick or has a mass per unit area of at least 1 kilograms per square metre (kg/m²).”

72: Any changes to regulation 2(6) and 7(3) will require a statutory instrument to implement.

Consultation question 14

Do you agree that an exemption to the ban on combustible materials in an on external walls above 18m should be made for laminated glass in the situations specified, yes or no?

Consultation question 15

Do you agree that the definition above is clear on the scope of products to be exempt from Regulation 7(2), yes or no?

Consultation question 15a

If you disagree, please provide your evidence.

Consultation question 16

Do you have any comments on the draft guidance text?

Consultation stage impact assessment

73: The changes proposed to section 10 of Volume 1 and section 12 of Volume 2 of ADB affect all building types covered by the guidance. For all building types above 18m, we do not anticipate any impact.

74: Through our review of industry practices, we have identified that the majority of the sectors affected are already working in line with the updated guidance. This has reduced the potential impact of the changes to only those who are outliers.

75: Our assessment of the overall impact of the changes is estimated to provide a total present cost of £35 million over 10 years, with an EANDCB of around £4.1 million.

76: The highest cost of the policy will be to residential buildings under 11m accounting for 67% of the policy cost. This is due to the number of buildings affected, with the cost per building estimated an average of £1,335 and affecting less than 1% of residential buildings below 11m.

77: The costs of meeting the improved fire classifications outlined within the guidance are focused on:

• substrates
• external covering products
• balcony construction

78: The proposed exemption to the ban on combustible materials in and on external walls for laminated glass to be used in certain situations is not expected to have a cost associated with it. It will however increase the choice of products available for use by industry and therefore will provide some benefits.

79: All estimates are in 2025 prices and 2027 present values. The policy implementation period is 2027 to 2036. The costs and benefits of the policy are appraised over the lifetime of the building elements that are affected by the changes.

7. Means of escape for disabled people: New provision for evacuation lifts in tall residential buildings

80: The introduction of provisions within ADB for a second staircase to be provided within residential buildings above 18m supported the evolution of safety within new buildings. Through the consultation responses and wider engagement with the sector, industry and residents, there was clear support for the guidance to introduce a provision for evacuation lifts.

81: Evacuation lifts for residential buildings are a recent technological innovation that may allow the independent evacuation of people who are unable, or may find it challenging, to use the stairs. Historically the guidance did not call for evacuation lifts, instead relying on a stay-put strategy and intervention from the fire and rescue service to assist with building evacuation.

82: To align with the principle of inclusive design guidance, building design should consider the needs of everyone who may access and exit the building. In keeping ADB up to date with current construction and design practices, and recognising that a range of industry and planning guidance already calls for evacuation lifts to be provided, BSR aims to align the guidance with these.

83: The introduction of evacuation lifts will have a positive impact on society, especially for protected groups characterised under the equalities act for age, disability and pregnancy and maternity.

84: BSR is proposing to introduce a new provision for evacuation lifts. ADB will call for a minimum of two stairs and two evacuation lifts in all new residential buildings above 18m. Where a firefighting lift is already provided, the lift can have a dual function.

85: Setting the threshold at 18m aligns with the threshold for the high-risk building regime. The threshold also aligns with recent changes to the guidance, which come into force in September 2026, on the provision of a second staircase in residential buildings that are 18m or more in height.

86: The draft introduces specific guidance around the height threshold for the inclusion of evacuation lifts in residential blocks of flats as well as provisions to support their safe use, and principles of evacuation lift design.

Consultation question 17

Do you agree that Approved Document B should include provisions for evacuation lifts, yes or no?

Consultation question 18

Do you agree that the threshold for provisions of evacuation lifts should be at 18m, yes or no?

Consultation question 19

Do you have any additional views on the proposed provisions?

87: Engagement with industry has highlighted a knowledge gap in the design of smoke control systems for buildings with complex footprints. Features such as second staircases and evacuation lift lobbies present challenges to the codified solutions in ADB and may require more bespoke design approaches.

88: This is why as part of the technical review, we intend to commission new research into smoke control approaches for blocks of flats. The objective will be to assess the current provisions as well as current practice to develop a more detailed, and transparent codified guidance on smoke control provisions.

Consultation question 20

Do you have any views on whether Approved Document B should include further provisions on the design of smoke control systems to support modern building design?

Consultation question 21

Do you have any comments on the draft guidance text?

Consultation stage impact assessment

89: Overall, the preferred policy option to introduce an 18m height threshold, is estimated to provide a total present cost of £31.5 million over 10 years, with an EANDCB of around £3.7 million.

90: The options being explored:

a) Option 1 (Preferred): Introduce a threshold of 18m above which evacuation lifts should be provided in residential buildings

b) Option 2: Introduce a threshold of 11m above which evacuation lifts should be provided in residential buildings

c) Option 3: Introduce a threshold of 18m above which evacuation lifts should be provided in residential buildings. For buildings above 30m, mechanical smoke extract systems should be provided.

91: Across the 3 options, the total present cost to business varies from around £41 million for an 11m threshold. The EANDCB is estimated around £4.8 million for an 11m threshold.

92: All estimates are in 2025 prices and 2027 present values. The policy implementation period is 2027 to 2036. The costs and benefits of the policy are appraised over the lifetime of the building elements that are affected by the changes.

93: Under each policy option, developers will install evacuation lifts and associated provisions in any new tall residential building designed in accordance with ADB. The policy options differentiate by the height threshold at which an evacuation lift must be installed, from 11m, 18m, 18m with mechanical ventilation above 30m, buildings. The costs covered are broken into 2 groups, annual costs and transition costs.

Annual costs:

• capital cost of upgrading one or more lifts to an evacuation lift
• capital costs of associated provisions
• maintenance costs of the evacuation lift or lifts

Transition costs:

• redesign costs

94: The uplift in cost per building of the provisions is in the range of 0.1% and 0.2% of total build cost. The cost of the provision of evacuation lift or lifts is unlikely to affect the viability of high-rise buildings. It is unlikely to reduce the amount of affordable housing that can be provided by developers.

95: Benefits have not been monetised due to limited evidence. Instead, these are captured through illustrative analysis. Other non-monetised benefits have been detailed qualitatively. The main benefits of this policy are expected to be:

• reduction in injuries and fatalities from fires for residents and risk to the fire and rescue service

• improved evacuation strategies for physically disabled residents, for instance, in cases of isolated fires, evacuation lifts can be used to avoid smoke inhalation

• wellbeing improvement due to reduced fear of future fires for residents and family members

Consultation question 22

Do you have views on what impact this text may have on industry?

8. Sheltered housing: Replacing ‘sheltered’ housing terminology and introducing new provisions for these housing types

96: Since the introduction of ‘sheltered housing’ as a description of residential housing types within ADB, the building types captured under this terminology have evolved. We no longer believe that ‘sheltered housing’ is the most appropriate term for these types of buildings, noting the range of resident profiles covered by a single definition.

97: We are seeking to introduce a new set of definitions. The update aims to replace the term ‘sheltered housing’ with ‘specialised housing’ to better reflect the broad range of housing types where resident needs may warrant further fire safety measures.

98: The term ‘specialised housing’ is defined as:

“Specialised housing includes two or more dwellings in the same building, purpose built as (or converted into) residential accommodation for people who receive, or will receive, a support and/or care service. Specialised housing is differentiated between those with or without personal care, see below.”

99: The new term intends to capture residential building types such as extra care, age exclusive, enhanced sheltered, sheltered, and close care. This is not an exhaustive list, but illustrative of the types of buildings that we consider within scope of the new definition.

100: The definition is broken down further to differentiate between the expected differences between resident needs across the building types.

“Specialised housing with care

Includes two or more dwellings, purpose built as (or converted into) residential accommodation for people who receive, or will receive, the regulated activity of personal care. This regulated personal care service may be provided through the housing provider or separately via external care agencies. This could include residential accommodation for older people or disabled people or people vulnerable to fire.”  

“Specialised housing without care

Includes two or more dwellings in the same building, purpose built as (or converted into) residential accommodation for people who receive, or will receive, a support and/or care service (not personal care). This could include residential accommodation for older people, disabled people, or people vulnerable to fire.”

101: The Care Quality Commission defines and regulates ‘personal care’. Recognising this regulated provision of care allows a differentiation between the level of fire safety provisions based on the inherent differences in risk profiles across the housing types captured under ‘specialised housing’. This differentiation will enable provisions to be targeted and proportionate. All existing provisions dedicated to buildings currently defined as sheltered housing will apply to all forms of specialised housing.

Consultation question 23

Do you agree that Approved Document B should introduce the new terminology for ‘specialised housing,’ yes or no?

Consultation question 24

Do you agree that the definition of ‘specialised housing’ should differentiate between housing types that provide the regulated activity of personal care and those that do not, yes or no?

Consultation question 24a

If you disagree, or have further comments on the clarity of the text, please provide any views and evidence on how the guidance could be further clarified or improved.

102: Alongside introducing the new definition, we are exploring how to further improve the fire safety provisions within these housing types. The Coroners and Justice Act 2009 provides a duty on coroners to make reports to a person, organisation, local council or government department or agency where the coroner believes that action should be taken to prevent future deaths. Those reports are made under Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013. A report sent to ministers in 2023 recommended that sprinklers should be considered with ‘extra care’ housing types.

103: Research was commissioned to aid understanding of fire safety risks in specialised housing and care homes.

104: The research did not provide conclusive evidence on the benefit of introducing specific fire safety provisions within these housing types. Recognising the importance of considering coroners’ recommendations in detail, BSR is considering two potential approaches to deliver a gradual evolution of safety standards within buildings in line with their recommendation.

105: The preferred approach would extend fire alarm coverage within specialised housing with care to improve detection and provide residents earlier warning of a fire in their home. The guidance will increase the provision to alarm systems with a category LD1 and grade D1 system inside the accommodation in line with BS 5836-6:2019.

106: This change is intended to reduce the risk of death or injury to residents in the flat or room of fire origin and support the wider benefits of earlier detection and notification.

107: Government commissioned research in 2006 to consider the life safety benefits of sprinklers in residential care homes (bre.co.uk). The results of this research found that many fires involved residents’ bedding and clothing, for example, through being ignited through smoking. The research showed that sprinklers were unlikely to operate quickly enough to prevent death or serious injury of the person directly affected.

Consultation question 25

Do you agree that Approved Document B should introduce increased alarm provisions in specialised housing with care, yes or no?

Consultation question 25a

If you disagree, or have further comments on the clarity of the text, please provide any views and evidence on how the guidance could be further clarified or improved.

Consultation question 26

Do you have views on which provision may be more suitable to implement?

• alarms
• sprinklers
• both
• other provision

Consultation question 27

Please provide any evidence you have to support your preferred provision.

Consultation question 28

Do you have any comments on the draft guidance text?

Consultation stage impact assessment

108: The overall impact of the preferred policy is expected to be £10.5 million over a 10-year period, with an ENACB of £1.2 million per year. If alarm provisions were to be extended to all specialised housing, the cost would be £36 million over 10 years.

109: In line with the coroner’s recommendation, we assessed the cost of introducing sprinklers into these housing types. To introduce provisions for sprinklers within specialised housing with care would come at a cost of £19.2 million over a 10-year period, with an ENACB of £2.2 million per year. To extend sprinklers to all specialised housing would cost £79 million over a 10-year period.

110: Recognising the low incidence of fires within these building types, the benefits of introducing alarms or sprinklers is directly comparable. Noting the additional maintenance costs associated with sprinklers, and the priority of protecting lives within the flat or room of fire origin, increased alarm provisions provide the best value for money improvement to life safety in these building types.

Consultation question 29

Do you have views on what impact this text may have on industry?

9. Additional fire safety guidance for roofs

111: Section 5 and 7 of ADB Volume 1 and section 8 of Approved Document B Volume 2 provide guidance on roofs. As part of the continuous review of ADB, BSR is reviewing the fire risk to modern roofs through several sources, including real fires investigations, construction technologies horizon scanning research, and engagement with industry bodies and standards-making committees.

112: Recent research looked to consider whether further guidance on fire stopping at junctions between modern roofs and compartment walls is needed (Fire safety: Compartment walls and roof junctions). The proposed changes to this section of the guidance seek to align the text style, improve legibility of diagrams, clarify definitions of roof components, and update guidance regarding fire stopping across compartment lines.

Consultation question 30

Do you agree that updated guidance more adequately considers modern roofs, yes or no?

Consultation question 30a

If you do not agree in response to question 30, please provide your evidence on how the guidance can be improved further.

113: The 2025 Future Homes and Buildings Standard builds on the 2021 Part L uplift and sets requirements for improved energy efficiency and low-carbon heating systems for new homes and non-domestic buildings to achieve ‘zero carbon ready’ status. Using solar energy will play an important role in the new standard, and it is expected that the uptake of PV panel installations will further increase.

114: BSR proposes fire safety updates in Section 12 for roofs incorporating energy generating installations. It is also acknowledged that other standards are restricting placement of electrical equipment in common areas unless additional safeguards are applied.

115: Specifically, this means enhancing the fire performance of products beneath and around the installations. For flat roofs, certain conditional exemptions are provided if other fire safety measures are in place. Additionally, the provisions aim to limit the presence of panels near roof openings to mitigate the potential for fire spread.

Consultation question 31

Do you have any comments on the draft guidance text?

Consultation stage impact assessment

116: The overall impact of the preferred policy is expected to be £28.9 million over a 10-year period, with an ENACB of £3.4 million per year. The cost of the updates to the guidance mainly falls on flats below 11m due to changes to the guidance for fire protection to flat roofs.

Consultation question 32

Do you have views on what impact this text may have on industry?

117: BSR proposes to undertake further research as required under the continuous review of ADB to develop the understanding of modern roof performance and examine if a new testing standard is required.

118: This will include BSR conducting a full review of the current guidance on roofing to make sure testing standards are adequate and the guidance caters for the fire safety performance of modern roofs and accessory components.

119: BSR is committed to working with industry in developing improved awareness of PV panels on buildings including good design, installation and maintenance regimes.

10. Car parks

120: Section 11 of ADB Volume 2 provides guidance on the fire resistance of open-sided car parks.

121: International incidents, the Liverpool Echo Arena and Luton airport car park fires are an indication of the potential consequences that non-localised fires in car parks can give rise to. The information collated on these events through our Real fires investigation project, and research conducted as part of the structural fire resistance and fire separating elements project, led us to undertake further detailed research on the fire safety of open-sided car parks. Using the research findings and considering the evidence provided in multiple Collaborative Reporting for Safer Structures (CROSS) reports,^{[footnote 2]} we are seeking to update the guidance for new car parks.

122: BSR proposes that the guidance calls for an increase in the fire resistance of multistorey open-sided car parks. These changes will result in:

• for open-sided car parks from 5m to 18m, an increase from 15 minutes fire resistance to 30 minutes fire resistance
• for open-sided car parks above 18m, an increase from 15 minutes fire resistance to 60 minutes fire resistance

123: The proposed changes to this section of the guidance address existing research findings, support the gradual evolution in safety for new buildings, and will ensure new car parks are suitably designed to accommodate modern cars. The changes will help implement other government policies, such as the safe rollout of electric vehicles, and safely adapt ADB to industry practice changes.

Consultation question 33

Do you agree that Approved Document B should increase the fire resistance of multistorey open-sided car parks, yes or no?

Consultation question 34

Are there any other fire safety provisions that should be considered for open-sided car parks?

Consultation question 35

Do you have any comments on the draft guidance text?

Existing car parks

124: Existing car parks are overseen and maintained under the Fire Safety Order and require regular checks and assessments to ensure they are maintained effectively. There is no evidence to suggest that existing car parks are inherently unsafe.

Consultation stage impact assessment

125: The overall impact of the preferred option is: £79.6 million over 10 years. The ENACB is £15.3 million a year.

126: Through our analysis we consider the potential trade-off where, if sprinklers are provided, the fire resistance expectations can be lower. It was concluded that the cost of incorporating and maintaining sprinklers would exceed the potential cost savings of a lower fire resistance threshold. Under this option, the 10-year present value cost was £242 million.

Consultation question 36

Do you have any views on the impact the changes to the text will have on the industry?

Assessment of impacts

127: A further assessment of impacts will be made following consideration of consultation responses and alongside the development of any provisions.

Consultation question 37

Please provide any additional evidence on costs, risks and benefits which should be considered in an assessment of impacts in the areas outlined in the consultation. Please provide evidence to support your response.

Consultation question 38

Are you aware of any particular equalities impacts for these proposals? How could any adverse impact be reduced and are there any ways we could better promote equality of opportunity or build good relations between people who share a protected characteristic and those who do not? Please provide evidence to support your response.

Consultation question 39

Are you aware of any particular environmental impacts for these proposals? How could any adverse impact be reduced and are there any opportunities to promote positive environmental impacts? Please provide evidence to support your response.

Next Steps

128: It is expected that the responses to this consultation will help inform the next updates to the guidance in ADB.

129: The consultation feeds into wider work BSR is undertaking on fire safety guidance as part of the continuous review of ADB.

130: We will publish a response to this consultation in due course.

HSE confidentiality and GDPR statements

131: HSE tries to make its consultation procedures as thorough and open as possible.

132: Information provided in response to this consultation may be subject to publication or disclosure in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the General Data Protection Regulations (GDPR) and the Environmental Information Regulations 2004 (EIR)). Statutory Codes of Practice under the FOIA and EIR also deal with confidentiality obligations, among other things.

133: If you would like us to treat any of the information you provide as confidential, please make this clear in your response. Ideally, confidential information should be submitted using the functionality provided at the end of the consultation for attaching confidential documents. If we receive a request under FOIA or EIR for the information you have provided, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances.

134: An automatic confidentiality disclaimer generated by your IT system will be disregarded for these purposes. Requests for confidentiality should be made explicit within the body of the response.

135: HSE will process all personal data in accordance with the GDPR. This means that personal data will not normally be disclosed to third parties and any such disclosures will only be made in accordance with the regulations.

How to submit comments

136: When responding to this consultation, please provide as much information and evidence as you can.

137: By submitting information as part of this consultation, you agree that any data provided (excluding your personal details) can be shared with the MHCLG, BSR, our independent scientific advisers, the appropriate authorities and other government departments as required for the response to this consultation. By submitting your response, you are confirming that you have read and understood the confidentiality and GDPR statements.

1. The government appointed members to the Fundamental Review of Building Regulations Guidance panel in July 2025. ↩

2. The Collaborative Reporting for Safer Structures reports include: Fire protection to car park steel frame (Cross-safety.org), Fire resistance of multi-storey car parks (Cross-safety.org), Fire risks in multi-storey car parks (Cross-safety.org) and Fire in multi-storey car parks (Cross-safety.org). ↩