Laboratories and Class E(g)(ii) research and development

Class E(g)(ii) covers research and development of products or processes, which is why a laboratory planning use class question usually starts with good news: an office in Class E can become a laboratory without a change of use application. The qualification that follows is where the work is. Class E(g) only reaches uses that can be carried out in a residential area without detriment to its amenity, so a laboratory that needs a stack, a chiller farm and a 24 hour air handling plant has probably left the class behind.

And even where the use is fine, the plant on the roof almost always needs permission in its own right.

What Class E(g)(ii) covers

The Use Classes Order places research and development of products or processes in limb (g) of Class E, alongside office use and light industrial processes. The defining feature of limb (g) is not the activity label but the amenity test: these are uses capable of being carried out in a residential area without detriment to amenity.

That makes the class self-limiting. A dry laboratory doing computational work and benchtop analysis sits comfortably within it. A pilot plant running a chemical process at scale, with a flare, a tanker delivery regime and continuous operation, does not, whatever the occupier calls it.

Movements within Class E need no permission, so the conversion of office floorspace to laboratory use is often lawful as a matter of use. Check the existing permission for a condition restricting the premises to one limb of Class E, because those conditions are now common and they are exactly what defeats a lab conversion.

Where a laboratory leaves Class E

The question to put to the authority is not what the occupier does but what the building does to its surroundings. The factors that push an operation out of Class E and into Class B2 general industrial, or into sui generis territory, are reasonably predictable.

• Discharge stacks and fume extraction that are significant in scale or carry an odour or emission risk.
• Rooftop or external plant with a noise output that could not be accommodated beside housing.
• Operation outside normal business hours as a matter of process rather than occasional working.
• Heavy goods vehicle servicing, bulk gas deliveries or cryogenic tanker visits.
• Storage of hazardous substances in quantity.
• Process work at a scale that reads as manufacturing rather than research.

None of those is individually decisive, and the assessment is cumulative. Where the answer is arguable, a lawful development certificate under section 192 of the Town and Country Planning Act 1990 is the only formal route to certainty, and a Planning Statement that sets out the activities, the plant and the servicing regime honestly is the document that persuades an officer either way.

Where part of a building becomes laboratory space and part stays as office, think about the planning unit, because splitting a commercial unit can change the analysis for both halves.

Containment levels and separate regulatory approval

Containment level is a health and safety classification, not a planning one, and the distinction is worth being firm about.

Work with biological agents is regulated under the Control of Substances Hazardous to Health Regulations 2002, which set containment requirements by hazard group, and work with genetically modified organisms in contained use has its own regulations with notification to the Health and Safety Executive. Higher containment work requires notification and, at the top levels, consent before work begins.

Local planning authorities sometimes attempt to condition the containment level of a laboratory. That is a duplication of another regulatory regime, and national guidance on the use of planning conditions discourages conditions that replicate controls elsewhere. The better approach is to accept conditions on the planning consequences, meaning plant noise, emissions, stack height, servicing and hours, and to explain that containment is regulated by the Executive.

Hazardous substances are different again. Where controlled quantities are exceeded, hazardous substances consent is needed under the hazardous substances regime, which is a planning consent administered by the authority. Check the quantities against the current thresholds early, because the consent takes time and the Executive is a consultee.

Plant, flues and roof equipment

Rooftop plant is where lab schemes meet planning resistance, and it is the part the design team tends to resolve last.

Stack height is the item to resolve first, because it drives the visual case and cannot be reduced later without reopening the dispersion assessment. Model it properly, show the stacks on every elevation, and include a view from the nearest sensitive window rather than only from the street.

Noise needs a Noise Impact Assessment with a full plant schedule and a rating level at each receptor. Emissions and odour, where relevant, need an Air Quality Assessment by a suitably qualified author, and professional review is strongly advised because the dispersion work is contestable.

Hazardous substances and waste handling

Laboratory waste is varied and some of it is regulated tightly. The application should say what streams are produced, how each is stored, whether anything is treated on site, and who removes it.

Typical streams: chemical waste by category, sharps and clinical waste, autoclaved biological waste, solvent waste, waste gas cylinders and general trade waste. Each needs a defined store with a capacity, a route for collection that does not cross a pedestrian entrance, and a registered carrier.

A Waste Management Strategy covering operational waste, with a plan showing store locations and vehicle access, answers most of the environmental health questions in one document. Where treatment such as autoclaving takes place on site, confirm whether an environmental permit or an exemption applies.

Floor loading and servicing requirements

This is not strictly a planning matter, and it shapes the planning application because it drives the form of the building.

Laboratory floor loadings exceed office loadings, and sensitive instrumentation imposes vibration criteria that a conventional long span office slab cannot meet. The usual consequences are a stiffer frame, shorter spans, ground floor locations for the most sensitive equipment, and a taller floor to floor dimension to take the services. That last point is the one that reaches planning, because it raises the building height for the same number of storeys.

Servicing adds a loading bay suitable for a rigid vehicle, a goods lift sized for equipment rather than trolleys, and a route for gas cylinder deliveries. Utility demand is also high, so an early enquiry to the distribution network operator belongs in the programme and, on larger schemes, in a utilities assessment.

Conditions on plant noise and emissions

Expect conditions along these lines, and read each as the person who will discharge it. A plant noise condition expressed as a rating level at a defined receptor, with a verification test after installation. A stack height condition tied to a drawing. A plant schedule condition requiring approval of any additional or replacement equipment. Hours for generator testing. An odour management plan where relevant. And a restriction on external storage.

Two drafting points. Insist that a noise condition names the assessment method and the measurement position, because a condition requiring plant to be inaudible is impossible to discharge. And agree a mechanism for replacing plant at end of life, since a condition approving named equipment leaves you applying to change a chiller in eight years. Hours conditions on testing deserve the same care, because varying an hours condition later is a fresh application.

This is general guidance rather than legal advice, so check the position with your local planning authority 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.