Use Classes and Change of Use

Offices to laboratories: Class E flexibility in practice

6 min readBy PlanScope Editorial Team

Offices and research and development both sit within Class E(g), so the use change is not development. The old occupancy condition and the rooftop plant are what need an application.

An office to laboratory change of use rarely needs planning permission for the use itself. Both offices and research and development sit within Class E of the Town and Country Planning (Use Classes) Order 1987 as amended in 2020, and movement within a class is not development. What does need permission is almost everything the laboratory has to bolt onto the building: extract stacks, roof plant, gas stores, condensers, a bin enclosure sized for clinical waste.

The planning risk in a lab conversion is therefore not the use. It is the condition on the original office permission, and the physical works the fit-out demands.

Why a laboratory usually sits in Class E(g)

Class E(g) covers uses which can be carried out in a residential area without detriment to its amenity, and it lists offices at E(g)(i), research and development of products or processes at E(g)(ii), and light industrial processes at E(g)(iii).

A dry laboratory, a computational biology floor or a wet lab running at containment level 1 or 2 with sealed extract normally falls comfortably within E(g)(ii). The building was already in E(g)(i) as offices. No application is needed to move between them, and section 55 of the Town and Country Planning Act 1990 confirms that a change within the same class is not development.

That is the whole of the flexibility. It is real, and it is why so much office stock has been marketed for life sciences conversion. But the words at the head of Class E do the heavy lifting, and they are conditional.

Where containment and process take a use outside Class E

The qualifier in E(g) asks whether the use could be carried out in a residential area without detriment to amenity. It is a test about the character of the activity in the abstract, not about the actual surroundings of your building.

Several things push a laboratory outside it:

  1. Containment level 3 or above, where the ventilation, security and effluent treatment requirements go well beyond anything an office setting absorbs.
  2. Pilot-scale manufacturing or process development at a volume that reads as production rather than research, which usually lands in Class B2.
  3. Storage or use of hazardous substances above the controlled quantities in the Planning (Hazardous Substances) Regulations 2015, which triggers a separate consent regime.
  4. Animal facilities, which raise their own amenity and security questions and are commonly treated as sui generis.
  5. Continuous plant noise or extract discharge that could not sit next to housing.

Where a proposal crosses one of those lines, the change of use becomes development and needs a full application supported by a Planning Statement explaining why the use falls where it does. Getting an early written view from the council on the use class point is worth more than any other pre-application question on a lab scheme.

Conditions that survived the 2020 reform

This is where schemes fail. The 2020 amendment to the Use Classes Order redrew the classes, but it did not sweep away conditions on existing permissions.

An office building consented in 2012 will often carry a condition worded along the lines of "the premises shall be used for purposes within Class B1(a) and for no other purpose". That condition still binds, and Class B1(a) no longer exists as a class, which does not make the condition unenforceable. It means the permitted use is fixed by reference to the old definition, and moving to research and development breaches it.

Removing or varying that condition needs an application under section 73 of the Town and Country Planning Act 1990. Section 73 is not a formality on a constrained site, because the council can attach new conditions and will look at the scheme afresh in policy terms, though it cannot revisit the principle of the original permission.

Check the decision notice before you check anything else. On any building consented in the last 20 years, read every condition, then read the section 106 agreement for use restrictions and employment clauses.

Plant, flues and the works that still need permission

Laboratory fit-out is plant-heavy. Air change rates for a wet lab are several times those of an office, and the extract has to discharge at a height and velocity that clears the building envelope and neighbouring intakes.

Expect to apply for:

  • Roof-mounted air handling units and chillers, with acoustic screening.
  • Fume cupboard discharge stacks, which are usually the tallest new element and the one most visible in townscape terms.
  • External gas cylinder and cryogenic storage compounds.
  • Any new louvre, riser penetration or facade alteration.

A Ventilation and Extraction Statement covering stack heights, discharge velocities and the assessment of nearby air intakes is the document that settles most environmental health objections. Where residential neighbours are close, add a Noise Impact Assessment assessing plant against the background sound level using the BS 4142 approach, and expect a condition fixing a rating level below background.

Councils usually accept that lab plant is unavoidable. They rarely accept it as drawn on the first attempt.

Servicing, deliveries and waste

Trip generation for a laboratory is not far from an office on a per-square-metre basis, so the transport case is mostly about servicing rather than staff movement.

The pattern that concerns highway officers is small, frequent, specialist deliveries: gas cylinders, dry ice, consumables, sample couriers running several times a day, and clinical or chemical waste collections by licensed carriers. Where an existing office loading bay was sized for one van a day, it will not do.

Set this out properly in a Transport Statement with a delivery and servicing schedule showing vehicle types, frequencies and the swept path into the bay. A waste strategy should identify the streams, the storage volume and the collection contractor type. Both documents are short, and both remove the most common reason for a highways holding objection on a lab conversion.

Floor loading, vibration and the structural reality

Office floors are typically designed for lighter imposed loads than laboratory equipment demands, and sensitive instruments impose vibration criteria that a long-span composite floor may not meet without stiffening.

Floor-to-floor height is the other constraint. Laboratory services need substantially more ceiling void than an office fit-out, and a 3.3 metre floor-to-floor building will not accommodate a wet lab without losing usable height. That drives the plant on to the roof, which drives the planning application.

None of this is a planning matter directly. It becomes one the moment the answer is a rooftop plant enclosure or an additional storey.

Permits that run alongside planning

Planning is one of several consents, and the others are not the council's problem to solve.

Trade effluent discharge to the public sewer requires consent from the sewerage undertaker under section 118 of the Water Industry Act 1991. Work with genetically modified organisms in contained use requires notification to the Health and Safety Executive. Use of radioactive substances requires a permit under the Environmental Permitting (England and Wales) Regulations 2016. Hazardous substances above the controlled quantities need consent from the hazardous substances authority.

Run these in parallel with the planning application. A stack height agreed with the council and then rejected by the operator's own risk assessment is a change to an approved drawing and another application.

Enter your postcode on PlanScope to see which supporting documents a laboratory fit-out at your building is likely to need.

This is general guidance, not legal advice. 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.

Frequently asked questions

Is a laboratory a Class E use?

Research and development of products or processes falls within Class E(g)(ii), provided the activity could be carried out in a residential area without detriment to amenity. Dry labs and containment level 1 and 2 wet labs normally qualify. Higher containment, animal facilities and pilot scale manufacturing usually fall outside Class E and need permission.

Do I need planning permission to convert offices to labs?

Not for the use itself where both the existing and proposed uses sit in Class E, because movement within a class is not development under section 55 of the Town and Country Planning Act 1990. In practice you will need permission for the extract stacks, roof plant, gas stores and facade alterations the fit-out requires.

Does an old Class B1(a) condition still apply?

Yes. The 2020 amendment to the Use Classes Order redrew the classes but did not cancel conditions on existing permissions. A condition restricting use to the former Class B1(a) continues to bite by reference to the old definition, and moving to research and development breaches it. Vary it under section 73 before you commit.

What documents does a lab fit-out application need?

Typically a planning statement covering the use class position, a ventilation and extraction statement giving stack heights and discharge velocities, a noise assessment of the plant against background sound levels, and a transport statement with a delivery and servicing schedule. Local validation lists add items, so check the council's list before submitting.

What consents run alongside planning permission for a lab?

Trade effluent consent from the sewerage undertaker under section 118 of the Water Industry Act 1991, notification to the Health and Safety Executive for contained use of genetically modified organisms, an environmental permit for radioactive substances, and hazardous substances consent where controlled quantities are exceeded. Run these in parallel with the planning application.

Sources and further reading

class echange of uselaboratorylife sciencesuse classes ordercommercial planning

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.

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