Fire Safety Strategy: the BS 9991 report structure
A BS 9991 strategy is a fire engineering document, not a planning fire statement. Here is what sits in each section and what a reviewer should test.
A fire safety strategy written to BS 9991 is a fire engineering document, prepared by someone with the fire engineering competence to stand behind it, and it is legally distinct from the planning stage fire statement. BS 9991 covers the design, management and use of residential buildings; BS 9999 covers the equivalent ground for non-residential buildings. A reviewer asked to check a fire safety strategy structure is checking whether each of seven blocks of content is present, internally consistent and matched to the drawings.
The commonest failure is a document that describes a compliant building in prose while the drawings show a different one.
Building description and the standard relied on
The opening section fixes the scope. It identifies the building, its height measured in the way the relevant guidance defines it, the number of storeys above and below ground, the floor areas, the use or uses, the occupancy characteristics and whether the building falls within the higher-risk category under the Building Safety Act 2022 framework.
It then states which route to compliance is being followed. That is either a code-based approach to BS 9991 or BS 9999, an Approved Document B approach, a fire engineered approach under BS 7974, or a hybrid with named departures. A reviewer should look for the departures to be listed explicitly rather than buried, because an unlisted departure is the item that surfaces at Gateway Two and stops the project.
Check the building height figure against the drawings yourself. Height determines almost everything downstream, and a strategy written against an early scheme that later gained a plant enclosure or a storey is the most common source of an out of date document.
Means of escape and the evacuation strategy
This is the longest section and the one to read first. It should state the evacuation strategy explicitly: stay put, simultaneous evacuation, phased, or progressive horizontal evacuation, with the reasoning for the choice.
Then it works through travel distances within flats and in common areas, the number and arrangement of stairs, the provision of lobbies, the protection of escape routes, final exits, and the arrangements for residents who cannot use stairs. Personal emergency evacuation planning and the provision of evacuation lifts belong here, and are an area where practice has moved quickly.
The evacuation strategy has a planning consequence as well as a building control one, because it drives core count and plan depth. A single stair building and a two stair building are different buildings, and the decision cannot sensibly be deferred past the planning drawings. Where the strategy changes, the Design and Access Statement has to change with it.
Compartmentation and structural fire resistance
The section should set out the compartment boundaries, the periods of fire resistance for elements of structure, the treatment of protected shafts, the approach to cavity barriers and external wall construction, and the provisions for firefighting shafts.
Look for four things as a reviewer. That compartment lines are shown on the drawings and match the text. That the fire resistance periods are stated by element rather than as a blanket figure. That the external wall materials position is stated, including any restriction on combustible materials in the relevant building class. And that the structural fire resistance assumption is consistent with the structural engineer's design rather than asserted.
Where a strategy says "to be confirmed by others", that is a gap rather than a coordination note. Mark it.
Fire service access and firefighting facilities
Appliance access routes, hardstanding positions, distances from the access point to the dry or wet riser inlet, hydrant locations and availability, firefighting shaft and lobby provision, and firefighting lift arrangements all sit here.
This section connects most directly to the planning layout, because appliance access is a site planning matter. A perimeter road that cannot take the weight or turning circle of an appliance is a layout problem, not a detail problem. Check the access proposals against the site plan, the tracking drawings and any adopted highway constraint, and check the hydrant position against the water undertaker's information rather than an assumption.
Gated developments and podium-level access arrangements deserve extra attention, because they are the arrangements most often changed between planning and construction.
Detection, alarm and suppression
The section records the detection and alarm category and the standard it is designed to, the alarm zoning, the provision of sprinklers or other suppression and the standard applied, smoke control to common corridors and stairs, and the interfaces between systems.
Two reviewer checks matter. First, that the category of the alarm system matches the evacuation strategy, because a stay put strategy and a building-wide simultaneous alarm are inconsistent by design. Second, that where suppression is being relied on to justify a departure elsewhere, the reliance is stated openly and the system is specified to a named standard.
Suppression has planning consequences in tank and pump space, and occasionally in external plant. Those need to appear on the planning drawings rather than arriving later.
Management arrangements and the strategy drawings
A fire strategy that depends on management has to say who manages it. The section covers the responsible person under the Regulatory Reform (Fire Safety) Order 2005, the arrangements for maintaining and testing systems, the fire risk assessment regime, the arrangements for informing residents, and the golden thread of information handed over at completion.
The drawings are part of the document, not an appendix to it. A reviewable set shows compartment lines, escape routes and travel distances, fire resistance periods, riser and shaft positions, alarm zones, suppression coverage and fire service access, each on a plan a firefighter could read. Where the drawings and the text disagree, say so in the review rather than reconciling them yourself.
How it relates to Gateway One and Gateway Two
Gateway One is the planning stage. For relevant buildings, Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015 requires a Fire Statement with the application, and the Health and Safety Executive is a statutory consultee. That document is about the principles of fire safety as they affect the planning matters, including site layout, access and the broad approach to escape.
Gateway Two is the building control stage for higher-risk buildings, where the full design is submitted to the Building Safety Regulator before construction. The BS 9991 strategy is the document that carries the detail into that submission, and a strategy that was written to support a planning application and never updated will be found out there.
A Fire Safety Strategy requires a professional with fire engineering competence. The Building Safety Act 2022 framework and the Regulatory Reform (Fire Safety) Order 2005 both place duties on named people, and an AI-assisted draft is a starting point for that professional rather than a substitute. Reviewers who sign off drafts can be found through the professional directory, and the wider report set is listed on the report index.
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. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
Frequently asked questions
Is a fire safety strategy the same as a fire statement?
No. The fire statement is the planning stage document required by Article 9A of the Development Management Procedure Order 2015 for relevant buildings, on which the Health and Safety Executive is consulted. The fire safety strategy is the fire engineering document, written to BS 9991 or BS 9999, that carries the detailed design into building control and Gateway Two.
When does BS 9999 apply instead of BS 9991?
BS 9991 covers residential buildings, including blocks of flats, student accommodation and sheltered housing. BS 9999 covers non-residential buildings, including offices, retail, assembly and industrial uses. Mixed use buildings often need both, with a clear statement of which standard governs which part and how the interfaces are handled.
Who is competent to write a fire safety strategy?
Someone with demonstrable fire engineering competence, usually a chartered or incorporated engineer with membership of a recognised fire engineering body, and with experience of the building type. Competence requirements under the Building Safety Act 2022 framework have tightened, and the Building Safety Regulator will test the basis of the design at Gateway Two.
Does a change of evacuation strategy affect planning?
Yes. Moving between stay put and simultaneous evacuation, or between one stair and two, changes core count, plan depth and often massing. That is a planning change, not a detail change, so settle the strategy before the planning drawings are fixed rather than discovering it during technical design.
What should a reviewer flag first in a submitted strategy?
Inconsistencies between the text and the drawings, unlisted departures from the code route, and any item marked to be confirmed by others. Check the stated building height against the drawings, because height drives most of the downstream provisions and an out of date height figure invalidates much of the document.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.