Fire engineering competence and who signs a strategy

A fire safety strategy written to BS 9991 or BS 9999 is a fire engineering document, and it should be authored and signed by someone with demonstrable fire engineering competence. That is a different person, a different document and a different regulatory moment from the fire statement submitted with a planning application under Article 9A of the Development Management Procedure Order 2015.

Architects get caught between the two. The planning consultant asks for a fire statement at week six, the client assumes the architect can write it, and nobody has appointed a fire engineer.

Where the strategy sits against the fire statement

The Fire Statement is a planning document. Article 9A of the 2015 Order requires it for applications involving a relevant building, broadly a building containing two or more dwellings or educational accommodation that is 18 metres or more in height or seven or more storeys. It is submitted on the form published by the Secretary of State, and the Health and Safety Executive, acting as the Building Safety Regulator, is the statutory consultee. That consultation is Planning Gateway One.

The fire statement addresses how fire safety has shaped the site layout, the access and water supplies for the fire service, the principles of the building design and the arrangements for evacuation. It is about planning matters, which is why it asks about site access rather than about door closer specifications.

The Fire Safety Strategy is the engineering document that sits behind it and continues past it. It sets out means of escape, compartmentation, structural fire resistance, smoke control, suppression, fire service facilities and the management assumptions the design relies on. It is developed through design, tested at Gateway Two and lives on into occupation.

Both are report types where a licensed or competent professional is legally required, and an AI-assisted draft is a starting point for that professional rather than a substitute for their judgement.

What competence means here

There is no single statutory licence for fire engineers in the way there is for licensed ecologists. Competence is demonstrated through a combination that a client should ask to see in writing.

Registration with the Engineering Council as a Chartered or Incorporated Engineer, obtained through the Institution of Fire Engineers, is the clearest external signal. Membership grade within the Institution matters too, because the grades are assessed against fire engineering experience rather than paid for. Beyond that, ask for project experience of comparable building type, height and occupancy, and ask specifically whether the individual named on the report is the one who did the work.

The Building Safety Act 2022 framework pushed competence from a professional courtesy into a duty. Designers and contractors working on higher-risk buildings must have the skills, knowledge, experience and behaviours for the work they take on, and must not accept an appointment beyond their competence. BS 8670 sets out core criteria for competence frameworks across the built environment, which is the document to reference when writing an appointment.

The standards the strategy is written against

Most residential strategies are written to BS 9991 and most non-residential strategies to BS 9999. Both are prescriptive-with-flexibility documents. Where the design departs from them, or where the building geometry defeats them, the strategy moves into performance-based fire engineering under BS 7974, which starts with a qualitative design review agreed with the stakeholders before any modelling happens.

Approved Document B remains the route to compliance most projects use for building regulations purposes, and a strategy that simply asserts compliance without demonstrating it will not survive Gateway Two.

Say which route the strategy uses on its first page. A reviewer who cannot tell whether they are reading a code compliance document or a fire engineering analysis will assume the former and test it accordingly.

Peer review and when to commission it

Independent peer review is worth its fee in three situations. Where the design relies on computational fluid dynamics or evacuation modelling rather than code compliance. Where a stakeholder with veto power, usually the regulator or the fire and rescue service, has already queried an approach. And where the client is buying a building they did not design.

Commission the review early enough that its findings can change the design. A peer review delivered a fortnight before the Gateway Two submission produces an argument, not an improvement.

The reviewer should be independent of the design team and should have no commercial interest in the outcome. Our note on independence and conflicts of interest in planning evidence applies with more force here than almost anywhere else.

Building control, the regulator and the gateways

For higher-risk buildings the Building Safety Regulator is the building control authority, and the three gateway points structure the programme. Gateway One is the planning stage consultation. Gateway Two is approval before construction starts, where the full design including the fire strategy is assessed. Gateway Three is completion, before occupation.

The practical consequence for design programmes is that the fire strategy cannot be left to be resolved on site. Changes after Gateway Two require a change control process, and the more the strategy relies on details that are usually settled during construction, the more change control the project will need.

The fire and rescue service is a separate consultee under the building regulations regime and will comment on access, water supplies and firefighting facilities. Engage it early, because its requirements can move a dry riser, a hydrant or an access road.

Liability, insurance and the appointment

Professional indemnity insurance for fire engineering has been hard to obtain and often carries exclusions, particularly around cladding and external wall systems. Ask for the certificate, ask what is excluded and ask about the level of cover per claim rather than in the aggregate.

Write the appointment so that it names the individual responsible, states the standards the strategy will be written against, sets out what is included and excluded, and says who owns the document and can rely on it. Where the strategy will be relied on by the client's funder or purchaser, that has to be dealt with at appointment rather than at practical completion.

The professional directory is one route to a reviewer who can check an AI-assisted draft before it goes anywhere near a submission.

Briefing at the right design stage

The single most common error is appointing the fire engineer after the massing is fixed. Escape strategy, core positions, compartment sizes and fire service access all have geometric consequences, and retrofitting them to a planning permission means either a second staircase in a place that ruins the layout or a material amendment.

Bring the fire engineer in at concept design. Ask for a one-page strategy summary at that stage covering the building height and classification, the evacuation strategy, the number and location of stairs, the suppression proposal and the fire service access requirement. That page is enough to inform the planning submission and to stop the layout going in a direction that cannot be defended later.

When you write the instruction, be explicit about deliverables and dates. Our guidance on writing a brief for a specialist planning report covers the structure, and for fire work add the gateway dates and the peer review milestone.

This is general guidance, not legal advice; check the position with your local planning authority, the Building Safety Regulator or a qualified professional 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.