Who is competent to write a BS 9991 fire safety strategy

A fire safety strategy written to BS 9991 is a fire engineering document, and it has to be written by someone with fire engineering competence. Not a fire risk assessor, not an architect who has read the code, and not a contractor's design manager. The strategy commits the building to an evacuation approach, a compartmentation pattern, a fire service access arrangement and a set of fire resistance periods, and every one of those decisions constrains the structure, the services and the facade.

Where a licensed or competent professional is legally required, that is the position here. A Fire Safety Strategy drafted from structured information is a starting point for that professional, never a substitute for them.

What a strategy document commits the design to

BS 9991 covers residential buildings and BS 9999 covers most other building types. Both are codes of practice offering a framework within which a designer can demonstrate an adequate standard of fire safety, and both allow approaches beyond the simple guidance in the statutory Approved Document.

A strategy typically fixes:

• The evacuation strategy, including whether a residential building operates on a stay put or simultaneous evacuation basis
• Means of escape, travel distances, stair numbers and widths, and the provision of protected lobbies
• Compartmentation, fire resistance periods and the treatment of protected shafts
• Smoke control, whether natural or mechanical, and the design assumptions behind it
• Suppression, including sprinkler or mist coverage and water supply requirements
• Fire service access, hydrant provision, firefighting shafts and premises information
• Management assumptions, which are the part most often forgotten and most often breached in use

Change any of those later and the strategy has to be revisited. That is why the document belongs at the start of a project, not at the point of a building control submission.

Institution of Fire Engineers grades

The Institution of Fire Engineers operates membership grades that map to demonstrated knowledge and experience: technician, graduate, member and fellow, with letters after the name to match. A member grade signals assessed competence in fire engineering rather than attendance on a course.

Grades are not qualifications on their own. Somebody with a member grade and twenty years in operational fire and rescue has different competence from somebody with the same grade and twenty years in building design, and both are different again from a graduate engineer two years out of a fire engineering degree. Ask what the individual has designed, not only what letters they hold.

Engineering Council registration adds a further layer. Chartered engineer status, obtained through an accredited institution, is assessed against a broad standard covering technical knowledge, judgement, responsibility and commitment. For performance-based design, where the strategy departs from prescriptive guidance and relies on calculation or modelling, chartered status is what most clients and approvers will expect to see.

Where a fire risk assessor is not the right author

The confusion between fire risk assessment and fire engineering costs projects money every year.

A fire risk assessment under the Regulatory Reform (Fire Safety) Order 2005 examines an occupied building as it stands and as it is managed, identifying hazards and shortfalls for the responsible person to address. It is an operational document about a real building.

A fire safety strategy is a design document about a building that does not yet exist. It sets the parameters that the design must meet. The two disciplines overlap in knowledge and diverge in method, and a competent fire risk assessor may have no experience of smoke modelling, structural fire resistance or evacuation calculation.

Where a project needs both, they are two appointments. Where a project has only a fire risk assessor's report and calls it a strategy, expect the building control body or the Building Safety Regulator to say so.

Peer review and when it is expected

Peer review is normal on complex schemes and is effectively assumed where the design uses fire safety engineering methods to justify a departure from prescriptive guidance.

Three situations where an independent review earns its fee: a performance-based smoke control design relying on computational modelling, an evacuation strategy for a building with an unusual occupancy or mobility profile, and any scheme where the structural fire design depends on calculated rather than tabulated resistance periods.

Reviewers should be independent of the design team and at least as qualified as the author. Record the review, the comments and the resolution, because on a higher-risk building the golden thread of information has to show how design decisions were reached, not merely what they were. The wider competence expectations under the building safety regime make that traceability a standing requirement rather than good practice.

How this differs from a planning stage Fire Statement

They are separate documents with separate legal bases. The Fire Statement required for relevant buildings under Article 9A of the Development Management Procedure Order 2015 accompanies a planning application and is considered at Planning Gateway One, with the Health and Safety Executive as statutory consultee. It addresses fire safety matters that are relevant to planning: site layout, access for fire appliances, water supplies, and the principles of the evacuation approach.

The BS 9991 strategy is a building design document sitting in the Building Regulations regime and later gateways. It goes into far more detail and is developed as the design develops. The competence considerations for each are related but distinct, and the position on Fire Statement competence at Gateway One should not be read across without thought.

Both sit within the framework created by the Building Safety Act 2022, which introduced dutyholder competence requirements supported by the competence framework standards published by the British Standards Institution.

Coordination with the structural and services design

A strategy that is never reconciled with the drawings is decoration. The reconciliation points that matter:

1. Fire resistance periods against the structural specification, element by element, including connections and any transfer structures.
2. Compartment lines against the architectural plans, checked for penetrations by ducts, cables and pipes at every floor.
3. Protected shafts and firefighting shaft provision against the riser layout and lift specification.
4. Smoke control assumptions against the mechanical design, including pressurisation airflows and door opening forces.
5. Escape door swings, door widths and travel distances measured on the plan rather than assumed from the schedule.
6. External wall construction against the strategy's assumptions on spread and on cavity barrier positions.

Run that check at every design stage, and run it again after any value engineering exercise. Most non-compliances found late are not design errors in the strategy. They are changes made elsewhere that nobody fed back to the fire engineer.

Checking who you are appointing

Ask for the individual's grade and registration, two examples of comparable buildings they have authored strategies for, their professional indemnity cover and its limit, and whether they will be available through to completion. A strategy author who leaves the project at planning stage creates a gap that somebody else has to fill at a worse moment.

If you are looking for a reviewer to sign off a draft, the professional directory is one route, and the same credential questions apply.

This is general guidance rather than legal advice, and fire safety competence requirements are set by statute and by the relevant approvers, so check the current position before relying on it.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.