Who can author a BS 9991 fire safety strategy

A fire safety strategy is a fire engineering document, so the answer to who writes a fire safety strategy is someone with demonstrable fire engineering competence, not the architect who drew the plans. That holds whether the strategy follows the code-compliant route or departs from it, and it holds more strongly the further it departs.

For the planning stage there is a related but narrower document. A Fire Statement is required at Planning Gateway One for relevant buildings under Article 9A of the Development Management Procedure Order 2015, which brings the Health and Safety Executive in as a statutory consultee. That statement has to be prepared by someone competent in fire engineering, and a licensed or competent professional is legally required for this kind of document. An AI-assisted draft is a starting point for that professional, not a substitute for them.

What a strategy document does

A fire safety strategy explains how the building achieves the fire safety objectives: means of warning and escape, internal and external fire spread, access and facilities for the fire service, and management in use.

It is the document that holds the design decisions together. Travel distances, compartment lines, stair capacity, smoke control, firefighting shaft provision, sprinkler coverage, external wall construction and evacuation philosophy all appear in it, with the reasoning for each.

It is also the document everyone else designs against. The architect's compartmentation, the services engineer's ductwork penetrations and the structural engineer's fire resistance all depend on it, which is why a strategy produced late is a strategy that triggers redesign.

A Fire Safety Strategy at planning stage is not the same document as the one building control assesses, but the two must not contradict each other. Where they do, the regulator notices.

Code compliance compared with fire engineering

Two routes exist and the competence needed differs between them.

The code-compliant route follows the statutory guidance in Approved Document B, or an alternative recognised standard such as BS 9991 for residential buildings or BS 9999 for other building types. The designer applies published provisions, and the judgement involved is about interpretation and application rather than first principles.

The fire-engineered route applies fire safety engineering principles under BS 7974, using quantified analysis such as smoke modelling, evacuation modelling or structural fire analysis to justify a design that departs from the codes.

Mixing standards is the error that causes most difficulty. Taking the travel distances from one code and the stair widths from another produces a design that satisfies neither, and a reviewer will unpick it.

Registration and competence frameworks

There is no single statutory register of people allowed to write fire strategies, but the competence landscape has tightened considerably.

What a client should look for includes membership of the Institution of Fire Engineers at an appropriate grade, registration with the Engineering Council as an incorporated or chartered engineer where the work is engineering analysis, demonstrable project experience with buildings of the same type and height, and professional indemnity insurance that expressly covers fire engineering.

The Building Safety Act 2022 framework brought competence duties into sharper focus, and British Standards now set out core criteria for building safety competence frameworks. The practical effect is that clients and principal designers are expected to check competence rather than assume it.

Ask three questions of any prospective author. Which standard will you work to, and why that one. Have you taken a building of this height and use through Gateway One before. And what does your insurance cover.

The question of who signs and dates the document matters as much here as anywhere, for the reasons set out in why every planning report needs a named author and date.

Where a performance based approach needs more

A performance based strategy needs a higher level of competence and usually independent scrutiny.

Three situations call for it. Where travel distances, compartment sizes or stair numbers depart from the codes. Where the building has an atrium, a complex ventilation arrangement or an unusual evacuation strategy such as phased or progressive horizontal evacuation outside the normal pattern. And where the structural fire design relies on analysis rather than tabulated periods of fire resistance.

In each case the strategy has to state its acceptance criteria before the modelling, explain the input assumptions, and show sensitivity to those assumptions. Modelling presented without stated criteria is advocacy rather than engineering.

Expect the regulator to ask who validated the model and against what. That is a reasonable question and an author who cannot answer it has a problem.

Third party review and when to commission it

Independent peer review is normal practice for fire-engineered designs and increasingly expected for taller buildings generally.

Commission it in four circumstances: where the design is performance based, where the building is higher-risk under the building safety regime, where a funder or insurer requires it, and where the design team's own fire engineer is also the designer of the departure being justified.

A review is worth more early. Reviewing a strategy at technical design, when the compartment lines are built into the drawings and the services are routed, produces findings that cost money to act on. Reviewing it at concept produces findings that cost drawing time.

Professional review before submission is the honest route for any applicant working from a drafted document. The reviewer directory on PlanScope's professional directory exists for that purpose, and for a fire document the reviewer has to be a fire engineer rather than a generalist, because signing off outside your competence is the specific risk described in supervision chains and graduate work signed by a chartered author.

Coordination with building control and the regulator

Three bodies may need to be satisfied and they look at different things at different times.

At planning, for relevant buildings, the Fire Statement accompanies the application and the Health and Safety Executive is consulted on it. The focus there is on site layout, access for fire appliances, water supplies, and whether fire safety has shaped the design rather than being applied afterwards.

At building control stage the detailed strategy is assessed, by the Building Safety Regulator for higher-risk buildings and by a building control body otherwise. The fire and rescue authority is consulted under the Building Regulations.

In occupation the Regulatory Reform (Fire Safety) Order 2005 applies, and the strategy becomes the basis of the fire risk assessment and the information handed to the responsible person.

Keeping those three consistent is a project management task. The commonest failure is a planning stage statement that describes a strategy the detailed design then abandons, which creates an awkward conversation with the regulator at the next gateway.

Liability and the scope of appointment

Be precise about what the appointment covers, because fire engineering liability is long-tailed.

Four points to settle in writing. Whether the appointment covers the planning stage statement only or continues through detailed design and into handover. Whether the author is responsible for coordinating other disciplines' compliance with the strategy, or only for writing it. What the inspection and verification duties are during construction. And what happens to the duty to update the strategy when the design changes.

An architect who incorporates a fire engineer's strategy into a submission is not thereby the author of it, and the document should say who wrote what. Where a strategy is drafted in-house and reviewed externally, the review letter needs to state its scope, because a review limited to the escape strategy does not cover the external wall construction.

The honest uncertainty is pace of change. The building safety regime continues to develop, and the competence expectations, gateway procedures and guidance have all moved in recent years. Check the current position with the regulator rather than relying on a precedent from an earlier project, and state the date and the version of each standard your strategy relies on.

Enter your postcode on PlanScope to see which fire and safety documents a scheme of your height and use 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. A Fire Statement and a fire safety strategy are documents for which a competent fire engineering professional is legally required, and PlanScope's draft is a starting point for that professional rather than a substitute. 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.