Fire safety strategy and fire statement: which one when

A fire statement is a planning document and a fire safety strategy is a design document. The fire statement versus fire strategy question matters because the two are produced at different stages, read by different people, and tested against different things: Article 9A of the Development Management Procedure Order 2015 requires the statement with certain planning applications, while a strategy to BS 9991 or BS 9999 demonstrates how the building will comply with Part B of the Building Regulations.

Confusing them wastes money in both directions. Teams submit a 90 page strategy with a planning application and get asked for the form anyway, or submit a form with nothing behind it and find the statutory consultee unimpressed.

The two documents and who reads them

The fire statement is read by the local planning authority and by the Health and Safety Executive as the statutory consultee at Planning Gateway One. Its job is to show that fire safety has shaped the proposal at the point where the layout, the access and the massing are still capable of being changed.

The fire safety strategy is read by the building control body, and for a higher-risk building by the Building Safety Regulator at Gateway Two. Its job is to set out how the building achieves the functional requirements of Part B, in the detail a designer and an approved inspector need.

Both are documents for which a licensed or competent professional is legally required. The statement has to be prepared by someone with the necessary fire engineering competence under the Building Safety Act 2022 framework, and a BS 9991 or BS 9999 strategy is a fire engineering document by definition. An AI-assisted draft of either is a starting point for that professional and not a substitute for one.

What Article 9A requires at planning stage

Article 9A applies to an application for planning permission for development involving one or more relevant buildings. A relevant building contains two or more dwellings, or educational accommodation, and meets the height condition of 18 metres or more, or seven or more storeys.

Where it applies, the application must be accompanied by a fire statement on the form published for the purpose. Submit the wrong form, or none, and the application is liable to be returned as invalid, which is the most common way this requirement bites in practice.

The matters the statement addresses are the planning-relevant ones. Site layout and the space around the building, access for fire appliances, water supplies for firefighting, the principles of escape and compartmentation at the level the design has reached, and the construction method and materials in outline terms.

What a BS 9991 strategy covers

A strategy goes into the things a planning officer has no business deciding. Compartmentation lines and fire resistance periods, stair numbers and widths, evacuation strategy, smoke control, detection and alarm categories, sprinkler or suppression provision, firefighting shafts, external wall construction, and the fire safety management assumptions the design depends on.

It is written against a standard, with departures identified and justified. Where a fire engineered solution departs from the guidance in Approved Document B, the strategy is the document that records the analysis.

The strategy also carries forward into occupation, because the golden thread of information and the building safety case for a higher-risk building draw on it.

Where the two overlap, and where duplication wastes effort

Three subjects appear in both documents: site layout, appliance access and water supplies. They appear for different purposes.

At planning stage the question is whether the site can accommodate the access and the hydrant provision at all, given the layout, the levels, the trees and the boundaries. At design stage the question is whether the specific appliance route, turning head and hydrant positions meet the standard.

So the sensible approach is to produce the access and water supply analysis once, at the right level, and let the planning statement reference the drawing the strategy will later develop. Three things are worth doing early even though the strategy is months away.

1. Fix the fire appliance access route on the site plan before the landscape design hardens, because retrofitting a 3.7 metre wide route with the required turning geometry usually costs a parking space or a tree
2. Confirm hydrant locations with the water undertaker early, since a new main is a long-lead item
3. Decide the evacuation strategy in principle, because single stair against two stair changes the core, the plan depth and the unit mix

What wastes effort is producing full compartmentation drawings and smoke control calculations for the planning application. They will change, and nobody at Gateway One is assessing them.

Competence, and what a reviewer should look for

For the statement, the question is whether the author has fire engineering competence appropriate to the building, and whether the statement is consistent with the submitted drawings. A reviewer should check the arithmetic of the height condition, since 18 metres is measured in a defined way and a scheme at 17.8 metres is in a different regime from one at 18.1 metres.

For the strategy, competence means a chartered or equivalently qualified fire engineer, with the departures from guidance clearly flagged and justified rather than buried.

In both cases the reviewer's most useful question is the dull one. Does the document describe the building that is actually being applied for? Statements referring to a stair core that was redesigned two revisions ago are common, and they undermine everything else in the submission.

An illustrative example

A 21 metre, seven storey residential block of 48 flats on a constrained urban site, with a single core and podium parking. The example is illustrative.

The fire statement explains the appliance access from the adopted road, the hydrant positions, the clear space around the building, and the fact that the scheme is designed around a single stair with the evacuation strategy and compartmentation to be developed. The strategy, six months later, sets out the stair width, the firefighting shaft, the smoke control in the lobbies, the sprinkler provision and the external wall construction, and justifies any departure from Approved Document B. The planning submission that fails is the one containing the second document's level of detail and none of the first document's clarity about the site.

Sequencing across the gateways

Gateway One sits at planning. Gateway Two sits before construction begins, when the Building Safety Regulator must approve the design for a higher-risk building. Gateway Three sits at completion, before occupation.

The practical implication is that decisions made for the planning application constrain the strategy that follows. A core position fixed by a planning permission, with a condition tying development to the approved drawings, is hard to move when the strategy wants another half metre of stair width. So the strategy's author should see the planning drawings before they are submitted, even if their formal appointment comes later.

Where an existing building is being retained and extended, the fire strategy has to work with the fabric that is there, and that interacts with the structural appraisal, as structural appraisal of a building proposed for retention sets out.

The product pages for each document explain what they contain and who can prepare them: the Fire Statement for the Article 9A submission and the Fire Safety Strategy for the design stage work.

Enter your postcode on PlanScope to see which supporting documents a scheme at this scale is likely to need.

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