Fire safety strategy or fire statement: what differs

Fire safety strategy vs fire statement is a distinction worth getting right before anyone commissions either. A fire statement is a short, planning-stage document required by law for certain buildings, submitted on a prescribed form and read by the local planning authority and the Health and Safety Executive. A fire safety strategy is a technical fire engineering document prepared for the Building Regulations stage, read by the building control body or the Building Safety Regulator, and it is a different animal entirely.

They overlap on perhaps a fifth of their content. The overlap is where contradictions appear.

The two documents and what each is for

The fire statement exists so the planning system considers fire safety at the point where it can still change the things only planning can change: where the building sits, how a fire appliance reaches it, where the water comes from, and the broad shape of the escape strategy. It is a planning document about fire, rather than a fire document submitted to planners.

The fire safety strategy exists to demonstrate that the building as designed satisfies the functional requirements for fire safety. It covers means of escape in detail, compartmentation, structural fire resistance, detection and alarm, suppression, smoke control, facilities for the fire service and the management regime that holds it all together.

The statutory basis of each

The fire statement comes from Article 9A of the Town and Country Planning (Development Management Procedure) (England) Order 2015, which requires a fire statement for applications relating to a relevant building, submitted on the form published for the purpose. The Health and Safety Executive is a statutory consultee at that stage, which is what Planning Gateway One means in practice.

The fire safety strategy has no equivalent planning requirement. It is prepared because the Building Regulations have to be satisfied, and because for a higher-risk building the Building Safety Regulator will not grant building control approval without it. The strategy is normally written to BS 9991 for residential buildings or BS 9999 for other buildings, or developed through a fire engineering approach where a code-compliant solution is not being followed.

The wider framework for both sits in the Building Safety Act 2022 and the three gateway structure it created.

Who reads each one, and when

This is the part that changes how you write them.

The planning officer reading a fire statement is not a fire engineer. The Health and Safety Executive consultee is. So the statement has to be legible to the first and defensible to the second, which argues for plain language with the technical basis stated rather than assumed.

The Building Safety Regulator reading a strategy at Gateway Two is reviewing the design against the functional requirements, with a statutory determination period and the power to reject. Its reviewers read the strategy alongside the drawings and the specifications, and inconsistency between them is a common reason for a request for further information.

Timing matters too. A fire statement is submitted with the planning application, often 18 months or more before the strategy is finalised. Whatever the statement commits to has to survive that gap.

Content overlap and where it diverges

Four topics appear in both: site layout and the siting of the building, emergency vehicle access, water supplies for firefighting, and the principles of the escape strategy. Everything else belongs to one or the other.

What is only in the statement, because only planning can deliver it:

• the relationship of the building to its site boundaries and to neighbouring buildings
• appliance access routes, hard standing and turning, as drawn on the site plan
• the location of hydrants and fire main inlets as they affect the frontage
• the policies the applicant has adopted on fire safety at a scheme level

What is only in the strategy:

• compartmentation lines, fire resistance periods and penetration sealing
• detection and alarm category, suppression design and smoke control sizing
• travel distances calculated rather than described
• the management and evacuation regime, including any dependency on staff

Neither document should attempt the other's job. A fire statement containing a full travel distance schedule is over-committed. A strategy that ignores the site constraints the planning permission fixed is unbuildable.

Sequencing across the gateways

The sequence that works is one direction of travel with nothing reversed.

1. Appoint the fire engineer before the planning drawings are fixed, so the core strategy, stair count and travel distances are known.
2. Write the fire statement from the fire engineer's outline position, stating principles and the standards to be followed.
3. Develop the strategy through the technical design, keeping the planning-fixed items intact.
4. Submit the Gateway Two application with the strategy, drawings and specifications consistent with each other.
5. Manage change control so that any strategy change affecting the approved planning drawings is identified early.

Step five is where schemes come unstuck. A strategy change that adds a second stair, moves a core or enlarges a smoke shaft changes the approved drawings, which needs a non-material amendment or a section 73 application, and the second of those is a determination with a fresh consultation. The structural consequences travel with it, which is why the questions raised in mass timber schemes belong in the same conversation.

Cost and programme consequences

A fire statement is a modest piece of work if the fire engineering outline already exists, and an expensive one if it does not, because writing it properly forces the strategy decisions early. That front-loading is a feature rather than a cost.

Gateway Two carries a statutory determination period for higher-risk buildings, and the current period should be confirmed with the regulator rather than assumed, because it has been adjusted since the regime began. Programme for the determination, not for a review. And programme for the possibility of a request for further information, which restarts the clock in practical terms even where it does not in law.

The expensive failure mode is a design that passes planning and then needs a different core to satisfy Gateway Two. At that point you are redesigning, reapplying and rescheduling at once. The record of warranties and technical documents matters here too, as set out in structural warranties and what the planning file should hold.

Avoiding contradiction between the two

Use one author or one firm for both, or at minimum have the strategy author review the statement before it is submitted. Keep the statement principles-based and label anything indicative as indicative. Record the fixed constraints the planning permission creates in a short schedule the technical design team works from. And re-read the statement at Gateway Two, because the one document nobody looks at again is the one that will be quoted back.

Illustrative example. A 10 storey residential block where the fire statement describes a single stair with mechanical smoke ventilation, and the strategy developed a year later concludes that a second stair is needed. The statement was not wrong at the time. The programme consequence is a section 73 application, a revised core, a changed unit mix and a new viability position. Appointing the fire engineer 6 months earlier would have cost a fraction of that.

Both documents need a competent author. A Fire Statement must be prepared by someone with the necessary fire engineering competence under the Gateway One framework, and a Fire Safety Strategy to BS 9991 or BS 9999 is fire engineering work throughout. PlanScope drafts both as a starting point for that professional and never as a substitute, inserting a flag wherever a design fact is missing.

This is general guidance, not legal advice; the competent designer, the building control body and the regulator determine what your building requires. Enter your postcode on PlanScope to see which reports your site is likely to need.

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.